In Matter of Baltes v. Smith (111 AD3d 1072, 975 NYS2d 782 [3d Dept 2013]), the Support Magistrate applied the then recently enacted section 451 (3) (a) and granted an incarcerated father's petition for a reduction of his support obligation. Family Court reversed, but only because the new provision applied prospectively only to petitions seeking modification of orders entered after October 13, 2010--the effective date of the statute. The Third Department affirmed, concluding that, because the newly enacted section 451 (3) (a) was not applicable, the old Knights rule (Matter of Knights v. Knights [1988]) applied, and barred the incarcerated father's claim of a change in circumstances. However, it referred to the Knights rule as "pre-amendment precedent"--implying that, in future, post-amendment cases, the opposite result would hold.