In Zimmer v. Zimmer, the Court of Appeals addressed whether a motion to modify child support for a child over the age of majority can be retroactive when a parent fails to bring a timely motion to end support. The primary argument was that support obligations should automatically end when a child reaches the age of majority and if not, the accumulated excess payments should be credited in arrears. The Court of Appeals reversed the trial judge, holding that a court cannot refund child support payments that were made after the age of majority, but prior to a motion to modify support. Child support orders do not automatically end when a child reaches majority. The lesson for parents who pay child support: be sure to file a motion to end your payments when your child is approaching age 18.