In Re the Marriage of Tracy Lynn Hoffman and Ernst Franklin Hoffman Upon the Petition of Tracy Lynn Hoffman N/K/A Bain, and Concerning Ernst Franklin Hoffman, 891 N.W.2d 849

Tracy Bain (formerly Hoffman) and Ernst Hoffman divorced in 2006; they share two children with Tracy having primary custody.
In 2012 Tracy moved ~70 miles to Albia; Ernie filed to modify physical care and child support; the district court granted modification but this was reversed on appeal.
This court (Hoffman I) remanded for determination of child support under the Guidelines and stated support should commence the date of the decree from which appeal was taken.
The Iowa Supreme Court affirmed the appellate court on custody but remanded for determination of child support "based on the present financial circumstances of the parties and the child support guidelines." (Hoffman II)
On remand the district court set Ernie’s support at $2921.40/month and made the award prospective only (not retroactive); Tracy appealed, arguing the court failed to follow the appellate mandate and that retroactivity was warranted on equitable grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court violated the supreme court’s mandate by making support prospective rather than retroactive	Tracy: The earlier appellate remand (this court) required support to commence as of the decree date; district court should have made award retroactive	Ernie: Supreme Court’s mandate required support based on present financial circumstances, allowing a prospective award	Court: Supreme Court’s mandate controlled; it required support based on present circumstances at remand, so prospective award complied with the controlling mandate — no error
Whether district court abused discretion by refusing equitable retroactivity	Tracy: Even if mandate unclear, equitable considerations entitled her to retroactive support	Ernie: Retroactivity is discretionary and not warranted here	Court: Retroactivity is permissive; district court exercised discretion not to make award retroactive and did not abuse that discretion

In re Marriage of Hoffman, 867 N.W.2d 26 (Iowa 2015) (supreme court affirmed custody ruling and remanded for child support based on present circumstances)
City of Okoboji v. Iowa Dist. Ct., 744 N.W.2d 327 (Iowa 2008) (trial court must follow appellate mandates)
Anderson v. State, 692 N.W.2d 360 (Iowa 2005) (scope of appellate review and effect on lower-court mandate)
In re Marriage of Davis, 608 N.W.2d 766 (Iowa 2000) (appellate opinion implications may be treated as clearly stated directives)
In re Marriage of Ober, 538 N.W.2d 310 (Iowa Ct. App. 1995) (retroactive child support is discretionary)
In re Marriage of Kurtt, 561 N.W.2d 385 (Iowa Ct. App. 1997) (factors for awarding appellate attorney fees)