In legitimation and paternity actions, it is sometimes necessary to consider retroactive child support.   This is almost always money to repay the mother for expenses incurred before a child support order went into effect.  

Retroactive child support has been available in Georgia since Weaver v. Chester, a 1990 Court of Appeals case.  Since then, courts have been required to consider both parties' incomes.  In Smith v. Carter, for example, an appeals court said that the actual expenditures of the mother were the ceiling for a back support award, not the floor, and that "a trial court is required to follow the Child Support Guidelines, which would include at least a consideration of the custodial parent's income, the noncustodial parent's income, and other child support obligations of the parents. See OCGA § 19-6-15(b)."