concurring.
I agree with the result reached by the majority but write separately to emphasize that I do so only under the peculiar facts presented. As noted above, “[a] wards of... child support are implicit commands of the court and are enforceable by action for contempt without language in terms of a command.” Griggers v. Bryant, 239 Ga. 244, 245 (1) (236 SE2d 599) (1977). In this case, the trial court incorporated into its judgment the parties’ settlement agreement in its entirety, including its provision that the agreed-upon child support payments were to commence on August 15, 2002. Thus, in the absence of the court’s subsequent clarification order, compliance with the settlement agreement would have been enforceable by contempt retroactive to that date. See Graves v. Graves, 239 Ga. 869 (239 SE2d 35) (1977) (incorporated settlement agreement requiring payment of sums due pre-judgment enforceable by contempt). Compare Eickhoff v. Eickhoff, 263 Ga. 498 (3) (435 SE2d 914) (1993) (settlement agreement not incorporated into divorce decree enforceable only by contract action), overruled in part on other grounds by Lee v. Green Land Co., 272 Ga. 107 (527 SE2d204) (2000). To hold otherwise would stymie efforts to enforce pre-judgment obligations under such agreements and invite noncompliance with terms intended to facilitate the provision of maintenance, protection, and education to minor children whom both parties are statutorily obligated to support. See OCGA §§ 19-7-2, 19-7-24. Thus, nothing in the majority’s opinion should be read as requiring a party to bring a separate contract action to enforce pre-judgment obligations that the trial court, having specifically approved as just and consistent with applicable law, has incorporated into its decree. Such a requirement would impose a needless burden on litigants, necessitate piecemeal litigation where a party has claims for both pre- and post-judgment noncompliance, *436and may well result in the default of claims for pre-judgment noncompliance, to the detriment of the children who stand to benefit from efficient enforcement of their parents’ support obligations.
Decided March 10, 2008 Reconsideration denied April ll, 2008. Kenneth H. Schatten, Cordell & Cordell, Tamar O. Faulhaber, for appellant. Moss & Rothenberg, Robert A. Moss, for appellee.Most agreements for child support are drafted in anticipation of incorporation into a court’s decree. In this case, the agreement failed to provide for such incorporation, and the trial court, having considered the circumstances, determined in its clarification order that its judgment did not include past-due amounts. Because of this ruling, I agree with the majority that contempt could arise only from noncompliance occurring post-judgment. For this reason only, I concur.
I am authorized to state that Chief Justice Sears joins in this concurrence.