In In re J.G.Z., 963 S.W.2d 144 (Tex. App. -- Texarkana 1998, no pet.) the trial court awarded a "judgment" for retroactive support of $ 55,000.00, which it characterized as an arrearage. In re J.G.Z., 963 S.W.2d at 147.
The Court first found that the trial court erred in characterizing the award as an arrearage, because the appellee did not specifically request a money judgment, and because the requested child support was to be set and then made retroactive, so there was no arrearage on which a cumulative judgment could be set under TEX. FAM. CODE ANN. § 157.263 (Vernon 1996). In re J.G.Z., 963 S.W.2d at 148.
The Court then held that the trial court's judgment was really a child support order, and that a judgment for arrearage could only be awarded if the appellant failed to make payments as required.