Marriage of Stubbs CA6, H051346

April and Micah Stubbs dissolved their marriage in April 2022 and share joint legal and physical custody of their minor children.
Their marital settlement agreement required mutual written consent for children's extracurricular activities and equal sharing of costs for mutually agreed activities but specified some activities only for 2022.
In April 2023, April (mother) requested a court order regarding children's extracurricular activities and payment of associated costs; Micah (father) opposed broad cost-sharing and sought limitations.
The trial court held a hearing where partial agreements were reached regarding the children's activities; the court orally ruled to equally share costs for only certain specified activities.
The written order, drafted by mother's counsel, ambiguously required sharing all activity costs but then specifically listed only certain activities; father appealed, asserting the order improperly modified the settlement without notice or changed circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the order expand cost-sharing beyond mutually agreed activities?	Order required equal cost-sharing for all activities, contrary to the judgment and without notice	Sought order for payment only for specific, court-approved activities	Order interpreted as applying only to specified activities, not all; no reversible error
Was there a modification without notice or changed circumstances?	Claimed due process violation—modification without notice or new circumstances	Sought enforcement for specific activities, not a general change	Objection forfeited; argument not preserved below; also, mother properly identified costs issue
Did the court err in deviating from oral ruling in written order?	Claimed written order varied from oral ruling and included activities not agreed	N/A	Written order controls if it deviates; record supports intent to control these specific activities
Did father forfeit issues by not objecting at trial?	Asserted objections on appeal, e.g., to lack of changed circumstances	N/A	Objections not raised in trial court are forfeited on appeal

Nakamura v. Parker, 156 Cal.App.4th 327 (Cal. Ct. App. 2007) (court decides appeal based on record if no respondent's brief is filed)
Kern County Dept. of Child Support Services v. Camacho, 209 Cal.App.4th 1028 (Cal. Ct. App. 2012) (arguments not raised in trial court are forfeited on appeal)
In re Marcus, 138 Cal.App.4th 1009 (Cal. Ct. App. 2006) (oral rulings do not become orders until reduced to writing)