*204Petitioner Phillip Spector (husband) filed for dissolution of his marriage to respondent Rachelle Spector (wife). The primary issue on appeal is whether the trial court's inherent authority to reconsider its own orders as explained in Le Francois v. Goel (2005)
FACTUAL AND PROCEDURAL BACKGROUND
The facts are generally undisputed.
Shortly after receiving the 2-21 Order on February 22, 2017, husband sent an email to the judge with a copy to wife, stating "there appears to be an error in your arithmetic" regarding the monthly temporary spousal support figure. (Bolding omitted.) Husband, wife, and the judge engaged in several *205e-mail exchanges regarding the calculations and the effect of the monetary awards and requirements in the 2-21 Order. Husband suggested "that the court relabel it's [sic ] ruling to instead be a Tentative Ruling and let us each argue before making it final." On February 23, 2017, the judge responded, "[q]uite frankly I have the authority to modify the orders and am considering doing so." She further stated "[w]e can call the notice and orders tentative," and invited the parties to argue the issues but indicated she "prefer[red] a 5 page written argument from each of [them]."
Husband responded that a five-page written argument was fine with him. Wife responded: (1) objecting to the use of e-mails for argument on substantive matters; (2) requesting the "ruling be treated like any other order after hearing issued in any family law or civil matter"; (3) requesting that any reconsideration of the ruling proceed under Code of Civil Procedure section 1008 and "by the briefing Code"; (4) stating, as a procedural matter, the parties and judge needed to review the hearing transcript, which would be available around March 3, 2017; and (5) explaining the "request for the standard briefing protocol and schedule" was to "assure that the parties' stipulation and order appointing a private judge is complied with and due process followed here" and to provide her counsel with sufficient time and ability to represent her.
The judge responded to wife, "[p]ursuant to the holding in Le Francois v. Goel (2005)
*858I am happy to provide you more time to provide your argument ... no due date has as yet been set. Obviously I need to read the transcript before I am able to reconsider the ruling. [¶] The written argument, from both counsel, will be due by March 15. That way I'll have the transcript and both written arguments to read together. [¶] In the mean time [sic ], the current orders while under reconsideration remain in full force and effect." Wife indicated "[n]o objection" to the "email re: scheduling and current order remaining in place while this matter is under reconsideration." Husband stated his objection that the 2-21 Order should be a tentative order without full force and effect, which the judge noted.
On March 3, 2017, wife provided the judge with copies of the reporter's transcript from the February 17, 2017, hearing. In the same e-mail, wife requested an "expedited hearing date and briefing schedule" to seek relief from the court "to address [husband's] failure to comply with the Order After *206Hearing by failing to make the first spousal support payment that was due on March 1, 2017." Such proposed relief included an order barring husband from attacking the 2-21 Order based on his noncompliance with the order pursuant to the disentitlement doctrine. The judge responded that wife would need to file a request for such relief in the trial court. Wife then asked for clarification regarding the 5-page limitation and for guidance on the issues to be addressed in the parties' submissions. The judge responded the 5-page limitation applied to argument only and added the parties were not allowed to submit additional declarations or exhibits. She further advised briefing should address "[t]he issue of what amount of pendente lite spousal shall be paid."
Both parties submitted briefs. Husband argued "[t]he only problem is that [the amount ordered in the 2-21 Order] greatly exceeds [husband's] monthly cash flow." Husband requested that the court either change the amount of the spousal support to below the guideline amount or order each party to pay his or her own attorney and professional fees, and for wife to pay all of the house-related expenses.
Wife argued there was no arithmetic error in the 2-21 Order and "there has been no additional findings or new evidence presented whatsoever " to support reconsideration under Code of Civil Procedure section 1008, "which governs and limits the grounds upon which a motion for reconsideration can be heard to new facts or law-neither of which exist[s] here." Wife disagreed that the court had authority under Le Francois to reconsider its ruling in the absence of a motion. She further argued husband should be barred from affirmative relief regarding the 2-21 Order under the disentitlement doctrine because he violated the 2-21 Order by failing to make the first required spousal support payment due on March 1, 2017.
On March 23, 2017, the court issued a "reconsidered" ruling and order (3-23 Order). In the 3-23 Order, the court explained it "was reconsidering its Ruling and Orders sua sponte pursuant to the holding in Le Francois v. Goel (2005)
*859The 3-23 Order sets forth wife's objections stating the court does not have the authority to reconsider the prior ruling, and the court's response that the Le Francois court "found that while legislation may limit what matters are *207brought by parties before the court, it may NOT limit a court's power to reconsider its rulings on its own." The court explained "[w]hile there was no math error" in the 2-21 Order, there were three other factors the court wanted to address. The 3-23 Order, among other things, modifies downward from the 2-21 Order the temporary spousal support amount awarded to wife, and imposes an effective date retroactive to March 1, 2017. Wife appeals.
DISCUSSION
We exercise independent de novo review of wife's claims that the trial court incorrectly interpreted and applied statutory and constitutional law.
I
The Court Had Authority Sua Sponte To Correct The Temporary Support Order
It appears wife's argument is three-fold: first, a trial court's inherent authority to reconsider its orders, as discussed in Le Francois , does not apply to a temporary support order because it is a final rather than interim order; second, the trial court lost jurisdiction to modify the 2-21 Order as a matter of law because it did not expressly reserve jurisdiction in that order, as required under In re Marriage of Gruen (2011)
To frame the analysis, we begin with the legal background regarding the interpretation of the Family Code statutes and the court's inherent authority to reconsider its own motions. We then apply those legal principles to conclude the court had authority sua sponte to correct the 2-21 Order.
*208A
Legal Background
1
Code Prohibition On Retroactive Modifications Of Temporary Spousal Support Orders
Pending final resolution of a marital dissolution case, the court may order one spouse to support the other. (§ 3600.) The purpose of a temporary spousal support order "is to maintain the living conditions and standards of the parties as closely as possible to the status quo, pending trial and the division of the assets and obligations of the parties." ( In re Marriage of McNaughton (1983)
A temporary spousal support order "may be modified or terminated at any time except as to an amount that accrued before the date of the filing of the notice of motion or order to show cause to modify or terminate." ( § 3603 ; see also §§ 3651, subd. (c)(1) [same but noting an exception inapplicable here], 3653, subd. (a) ["[a]n order modifying or terminating a support order may be made retroactive to the date of the filing of the notice of motion or order to show cause to modify or terminate, or to any subsequent date" subject to exceptions inapplicable here].) While numerous cases have discussed the application of this statutory prohibition against retroactive modification of temporary spousal support orders, wife points us to two specific cases- Gruen and Freitas .
In Gruen , a husband filed for dissolution of marriage and applied for an order to show cause concerning child and spousal support, among other matters. ( In re Marriage of Gruen , supra , 191 Cal.App.4th at p. 632,
The appellate court reversed, noting the original order was "final" and "immediately operative and directly appealable." ( In re Marriage of Gruen , supra , 191 Cal.App.4th at p. 639,
Gruen was later distinguished in Freitas . In Freitas , the trial court entered a temporary spousal support award in favor of husband but reserved jurisdiction over whether to amend the support award, stating husband could submit additional evidence pertaining to wife's income. ( In re Marriage of Freitas , supra , 209 Cal.App.4th at pp. 1061-1062,
First, in Gruen , the original support order was "final" and "directly appealable," whereas the Freitas trial court had expressly reserved jurisdiction to amend its original support awards based on further consideration of evidence. ( In re Marriage of Freitas , supra , 209 Cal.App.4th at pp. 1073-1074,
*210Second, in Gruen , husband had taken his original order to show cause off calendar and there was no pending motion to modify the support order. ( In re Marriage of Freitas , supra , 209 Cal.App.4th at p. 1075,
Distilled simply, Gruen and Freitas together establish the rule that a trial court lacks jurisdiction to retroactively modify a temporary support order to any date earlier than the date on which a proper pleading seeking modification of such order is filed ( In re Marriage of Gruen , supra , 191 Cal.App.4th at p. 631,
2
A Court's Inherent Authority To Reconsider Its Own Orders
The interplay between statutory directives and a court's inherent authority to reconsider its own orders was addressed by our Supreme Court in Le Francois . In Le Francois , a judge granted a motion for summary judgment on grounds previously denied by another judge in the same case more than a year prior. ( Le Francois v. Goel , supra , 35 Cal.4th at p. 1096,
After "uphold[ing] the statutes to the extent they apply to motions filed by the parties," the court explained "[w]hether these statutes can validly limit the court's authority to act on its own motion to correct its own errors presents quite a different question." ( Le Francois v. Goel , supra , 35 Cal.4th at p. 1104,
The court found Code of Civil Procedure section 437c, subdivision (f)(2), "can easily be so interpreted" because "that subdivision merely states that 'a party may not' make a motion that violates its provisions." ( Le Francois v. Goel , supra , 35 Cal.4th at p. 1105,
Our Supreme Court noted that a judge may act on his or her own motion "whether the 'judge has an unprovoked flash of understanding in the middle of the night' [citation] or acts in response to a party's suggestion," "although any such communication should never be ex parte." ( Le Francois v. Goel , supra , 35 Cal.4th at p.1108,
Because the court addressed only interim orders in the Le Francois decision, and noted in a footnote that "[w]hat we say about the court's ability to reconsider interim orders does not necessarily apply to final orders, which present quite different concerns" ( La Francois v. Goel , supra , 35 Cal.4th at p. 1105, fn. 4,
In Barthold , the judgment of dissolution provided wife would get a bonus if the *863house was listed for sale and sold within a certain amount of *212time. ( In re Marriage of Barthold , supra , 158 Cal.App.4th at p. 1304,
The Court of Appeal affirmed. Husband argued, among other things, the court's inherent authority to reconsider orders only extended to interim rulings. ( In re Marriage of Barthold , supra , 158 Cal.App.4th at p. 1312,
The court upheld the trial court's use of its inherent authority, explaining, while wife submitted new evidence in support of her motion, "the judge stated that the basis for his ruling was his rereading of the papers submitted with the original motion, and the order did not rely on or even mention [wife's] additional evidence." ( In re Marriage of Barthold , supra , 158 Cal.App.4th at p. 1309,
We later agreed with the Barthold court's decision in In re Marriage of Herr (2009)
B
Application To The Court's Reconsideration Of The 2-21 Order
Wife attempts to distinguish Le Francois and Barthold on the grounds that "[n]either of th[o]se two cases involved the modification of a final order awarding temporary spousal support" governed under the sections applicable here, and argues Gruen and Freitas are controlling. She further argues the court improperly reconsidered the 2-21 Order based on husband's "ex parte" communications. We disagree.
The principles espoused in Le Francois and Barthold are not circumscribed to the subject matter of the underlying cases or limited to the statutes at issue therein. In Le Francois , our Supreme Court analyzed statutes that traverse all types of subject matter areas, i.e., Code of Civil Procedure sections 1008 and 437c, subdivision (f)(2). ( Le Francois v. Goel , supra , 35 Cal.4th at p. 1096,
If the Family Code statutes were read to preclude a court from reconsidering a temporary support order sua sponte to correct its own error, the interpretation would clearly raise separation of powers concerns, as discussed *214in Le Francois . Further, if the statutes were read to allow a court to sua sponte reconsider a prior erroneous temporary support order, but to preclude the court from retroactively modifying the order, the statutes would strip the court of its ability to effect the use of its inherent authority. In other words, it would practically render such authority meaningless by placing temporal restrictions on the court's ability to correct its error-tying it to a party's filing of a motion or order to show cause. Such a proposition cannot be squared with Le Francois either because it would require a court to subject the parties to an erroneous order even when the court realizes it misunderstood or misapplied the law. This would result in the miscarriage of justice our Supreme Court warned against.
We heed our Supreme Court's directive in Le Francois , reading the statutes in a manner to avoid the constitutional issue of separation of powers. ( Le Francois v. Goel , supra , 35 Cal.4th at p. 1105,
Here, the trial court explained that it was reconsidering the 2-21 Order on its own motion because, while there was no math error, there were three other factors it wanted to address. As wife acknowledged, when the court reconsidered the 2-21 Order, "there ha[d] been no additional findings or new evidence presented whatsoever ." The trial court's reconsideration on its own motion was proper "because it limited itself to changing its mind based on the evidence submitted in connection with the [parties'] original motion[s]." ( In re Marriage of Herr , supra , 174 Cal.App.4th at pp. 1469-1470,
Wife further argues the court did not have inherent authority to reconsider the order because it acted in contravention of Le Francois when it revisited and modified the 2-21 Order based on "ex parte" communications from husband, i.e., the e-mails on February 22 and 23. Wife mischaracterizes the nature of the communications. ( Le Francois v. Goel , supra , 35 Cal.4th at p.1108,
*215"An ex parte communication is one where a party communicates to the court outside the presence of the other party." ( Nguyen v. Superior Court (2007)
It is undisputed that wife's counsel was included on all e-mails between husband's counsel and the court on the issue of reconsideration of the 2-21 Order. In fact, the pertinent e-mails were attached to her counsel's declaration in support of her opposition to reconsideration of the 2-21 Order, showing her counsel was copied on all those communications. Further, wife's counsel responded to a number of those e-mails detailing wife's opposition. While these communications occurred in an informal setting, there is simply no support for wife's assertion that those e-mails were ex parte communications.
The court's reconsideration of the 2-21 Order in response to husband's e-mails was furthermore permissible. "[I]f a court believes one of its prior orders was erroneous, it may correct that error no matter how it came to acquire that belief." ( In re Marriage of Herr , supra , 174 Cal.App.4th at p. 1469,
Turning to wife's argument that the court's inherent authority to reconsider its orders is limited to interim orders, we agree with Barthold that such authority may extend to final orders, such as the *866order at issue here. ( In re Marriage of Barthold , supra , 158 Cal.App.4th at p. 1312,
We also note the court's reconsideration did not run counter to the policy rationale underlying the Family Code statutes that the parties should be entitled to rely on the amount of a temporary support order without the threat of having to repay or credit the other spouse or to pay additional sums in the future. ( In re Marriage of Gruen , supra , 191 Cal.App.4th at p. 639,
II
The Court Did Not Violate Wife's Due Process Rights
Wife argues Le Francois required the court to inform the parties of the concern with the order, solicit briefing, and hold a hearing, and "the trial court did none of these things," violating her due process rights. Not true.
First, wife received notice of the court's intent to reconsider the 2-21 Order on February 23, 2017-the day after the order was served. The judge sent two e-mails on February 23, 2017, first stating, "I have the authority to modify the orders and am considering doing so," and later affirming, "[p]ursuant to the holding in Le Francois v. Goel (2005)
Wife repeatedly argues the 3-23 Order is procedurally deficient because the trial court did not formally file a motion or an order to show cause prior to issuing its revised ruling. But there is plainly no requirement for a court to file a motion to be considered by itself. Parties file motions and courts issue orders on those motions. ( Case v. Lazben Financial Co. (2002)
There are also no specific procedural requirements associated with a *867court's inherent authority to reconsider its own prior order-and wife does *217not cite to any authority to the contrary. As we noted in Herr , a judge's inherent authority to reconsider and correct erroneous orders are "independent of the statutory limitations imposed on reconsideration motions initiated by the parties." ( In re Marriage of Herr , supra , 174 Cal.App.4th at p. 1469,
Second, the court solicited briefing regarding its reconsideration of the order and the parties each filed a brief. While wife requested that any reconsideration proceed under Code of Civil Procedure section 1008 and "by the briefing Code," there are no specific page requirements when a court acts pursuant to its inherent authority. California Rules of Court rule 5.2(g), provides that "[i]n the exercise of the court's jurisdiction under the Family Code, if the course of proceeding is not specifically indicated by statute or these rules, any suitable process or mode of proceeding may be adopted by the court that is consistent with the spirit of the Family Code and these rules." Wife does not argue that she would have benefited from more allowable briefing pages, that she would have made additional arguments, or that she was prejudiced by the five-page limit. Thus, we have no cause to find error. (See Cal. Const., art. VI, § 13 [fundamental precept of appellate jurisprudence is error that is not harmful or prejudicial is not reversible].)
Third, while the court did not hold a hearing, it did invite the parties to argue the issues but indicated it "prefer[red] a 5 page written argument from each of [them]." Wife argues she requested that the court "adopt a briefing and hearing schedule that complied with the Code" but the record shows she only asked for "the standard briefing protocol and schedule." Wife did not ask for a hearing on the court's reconsideration of the 2-21 Order. Wife's request for a hearing schedule pertained to her request for an "expedited hearing date and briefing schedule" to seek relief from the court "to address [husband's] failure to comply with the Order After Hearing by failing to make the first spousal support payment that was due on March 1, 2017." The court responded that wife would have to file an appropriate motion because the matter was not before the court.
Accordingly, the court gave the parties the opportunity to request a hearing and wife cannot now complain of her failure to do so. Moreover, wife makes no argument or showing that she was prejudiced by the lack of an oral argument. Wife argued her position in the e-mail exchanges with husband and the court on February 23, 2017, and also in the briefing she filed with the *218court. We note the opportunity to be heard does not necessarily compel an oral hearing. (See Lewis v. Superior Court (1999)
Wife cites two cases for the proposition that "[s]imilar failures by trial courts to satisfy due process in taking sua sponte acts have resulted in reversal." Neither case is similar, as she contends. In Bricker v. Superior Court (2005)
In Moore v. California Minerals etc. Corp. (1953)
In contrast to the circumstances in Bricker and Moore , wife had ample notice of the court's reconsideration of the 2-21 Order, was allowed to file a brief in response (and did file such a brief), and was given the opportunity to make her arguments. There was no due process violation.
*219DISPOSITION
The trial court's order is affirmed. Husband shall recover his costs on appeal. ( Cal. Rules of Court, rule 8.278(a)(1).)
We concur:
Hull, Acting P.J.
Hoch, J.
All further section references are to the Family Code unless otherwise stated.
The disputed facts are not discussed because they are immaterial to resolution of the case.
Wife does not argue that the evidence was insufficient to support the court's reconsidered 3-23 Order.
Wife cites several other cases finding a trial court lacked jurisdiction to retroactively modify a temporary spousal support order, e.g., In re Marriage of Williamson (2014)
Relying on In re Marriage of Freitas, supra , 209 Cal.App.4th at pages 1068-1069,
Wife argues the court erred in finding the disentitlement doctrine was inapplicable. The disentitlement doctrine was codified in the context of dissolution of marriage proceedings in Code of Civil Procedure section 1218, subdivision (b), which provides: "Any party, who is in contempt of a court order or judgment in a dissolution of marriage, dissolution of domestic partnership, or legal separation action, shall not be permitted to enforce such an order or judgment, by way of execution or otherwise, either in the same action or by way of a separate action, against the other party." We agree with the trial court that the disentitlement doctrine was inapplicable here because the court notified the parties that it was reconsidering the 2-21 Order prior to the March 1, 2017, payment date, and the court retroactively modified the order. Further, husband was not attempting to enforce the 2-21 Order against wife-wife was the one seeking to enforce the order against husband.