Section 18.11 Appeal of Pendente Lite Order

• Library: Family Law Deskbook and 2014 Supp

IV. (§18.11) Appeal of Pendente Lite Order

A PDL (pendente lite) order is a separate and distinct proceeding from the dissolution of marriage proceeding, despite the fact that it is only filed and heard within a dissolution action. See:

Tate v. Tate, 920 S.W.2d 98 (Mo. App. E.D. 1996) (there was no error in the trial court failing to enforce a PDL order in the trial of the dissolution action because the complaining party must file a separate enforcement action)

Johnson v. Johnson, 894 S.W.2d 245, 247 (Mo. App. E.D. 1995) (the trial court erred in amending a final PDL judgment in its decree of dissolution)

Wray v. Wray, 73 S.W.3d 646 (Mo. App. E.D. 2002)

As...