In re Marriage of Vomacka (1984) 36 Cal.3d 459
Holding
Where jurisdiction to award (or grant requests for) spousal support is reserved until a specified date, the court has fundamental jurisdiction until that date to take new action concerning support, including extending the support term beyond the last date the court can act. To absolutely terminate jurisdiction, explicit termination language is required.
Relevance to this matter
Cited by name (along with Brown and Ousterman) in Stipulated Judgment ¶62 and ¶63. Both Charles and Jennifer expressly waived any rights they might have under Vomacka, Brown, and Ousterman. Those waivers — together with the no-upward-modification cap at ¶64 — are the operative bar against any post-judgment effort to extend the spousal support obligation past 1/31/2025. Vomacka is therefore the case the parties contracted around: Vomacka would have provided extension authority absent the express termination, and the express ¶62 / ¶63 termination forecloses it.