delivered the opinion of the court:
In January 2000, the trial court entered judgment in favor of plaintiff, Bonnie Jean Burwell, and against defendant, Lloyd C. Bur-well, and awarded Bonnie $15,100 in unpaid child support. The court later denied Bonnie’s request for prejudgment interest on the unpaid support.
Bonnie appeals, arguing that the trial court erred by not awarding prejudgment interest in accordance with section 12 — 109 of the Code of Civil Procedure (Code) (735 ILCS 5/12 — 109 (West 1998)). We reverse and remand.
I. BACKGROUND
In March 1977, the trial court entered an order dissolving the parties’ marriage, granting custody of their only child, John (born November 3, 1976), to Bonnie, and ordering Lloyd to pay $100 per month in temporary child support, beginning April 1, 1977. In November 1977, the court entered an order setting permanent child support at $100 per month.
In September 1999, Bonnie filed a motion for entry of judgment, seeking $23,200 in unpaid child support that had accrued between April 1, 1977 (the date of the initial temporary order for child support), and November 3, 1994 (the date that John reached 18 years of age). Bonnie also sought prejudgment interest on the child support arrearage and attorney fees.
In January 2000, the trial court entered an order pursuant to the parties’ agreement, awarding Bonnie $15,100 in unpaid child support. The court reserved ruling on the questions of interest and attorney fees. Following a hearing later that month, the court granted Bonnie’s request for attorney fees but denied her request for prejudgment interest “in the exercise of its discretion.” After pronouncing its ruling at the hearing, Bonnie’s counsel asked the court to comment on the impact of section 505(d) of the Illinois Marriage and Dissolution of Marriage Act (Dissolution Act) (750 ILCS 5/505(d) (West Supp. 1999) (effective until June 1, 2000)) on the court’s ruling. The court responded that (1) section 505(d) was enacted after 1994 and thus was not in effect while the child support order was in effect (April 1977 through November 1994), and (2) during the time that the child support order was in effect, the awarding of interest on child support judgments was a matter within the trial court’s discretion.
In February 2000, Bonnie filed a motion to reconsider, in which she argued that pursuant to (1) section 505(d) of the Dissolution Act (then section 505(c) (Pub. Act 85 — 2, § 2, eff. May 1, 1987 (1987 Ill. Laws 1, 6-7))) and (2) the amended version of section 12 — 109 of the Code (see Pub. Act 85 — 2, § 6, eff. May 1, 1987 (1987 Ill. Laws at 14); as amended see 735 ILCS 5/12 — 109 (West 1998)), both of which took effect on May 1, 1987, she was entitled to interest on the unpaid child support that accrued after June 1, 1987. Following a March 2000 hearing, the trial court denied Bonnie’s motion. In so ruling, the court explained that it was compelled to follow In re Marriage of Kaufman, 299 Ill. App. 3d 508, 701 N.E.2d 186 (1998). This appeal followed.
II. ANALYSIS
A. Lloyd’s Failure To File a Brief
•1 Initially, we note that Lloyd did not file a brief in support of the trial court’s order. In First Capitol Mortgage Corp. v. Talandis Construction Corp., 63 Ill. 2d 128, 133, 345 N.E.2d 493, 495 (1976), the supreme court held that when the record is simple and the claimed errors are such that a reviewing court can easily decide them without the aid of the appellee’s brief, the reviewing court should decide the merits of the appeal. Because we conclude that this is such a case, we address the merits of Bonnie’s appeal despite Lloyd’s failure to file a brief.
B. Standard of Review
•2 The facts are not disputed and the issue raised on this appeal is one of law — that is, whether the imposition of interest on child support judgments is mandatory under section 12 — 109 of the Code (735 ILCS 5/12 — 109 (West 1998)). We review questions of law de nova. Panhandle Eastern Pipe Line Co. v. Environmental Protection Agency, 314 Ill. App. 3d 296, 300, 734 N.E.2d 18, 21 (2000).
C. Prejudgment Interest
Bonnie argues that the trial court erred by failing to apply section 12 — 109 of the Code (735 ILCS 5/12 — 109 (West 1998)) and award her interest accordingly. For the following reasons, we agree.
In Finley v. Finley, 81 Ill. 2d 317, 332, 410 N.E.2d 12, 19 (1980), the supreme court held that whether to impose interest on child support judgments lies within the trial court’s discretion. In so holding, the court explained that divorce proceedings are similar to chancery proceedings and therefore should be governed, to a great extent, by the rules governing such proceedings. In chancery proceedings, interest on judgments is allowed when equitable considerations warrant it.
•3 Seven years after Finley, the General Assembly amended section 505 of the Dissolution Act and section 12 — 109 of the Code by enacting Public Act 85 — 2 (Pub. Act. 85 — 2, §§ 2, 6, eff. May 1, 1987 (1987 Ill. Laws at 5-6, 14)). The amendment to section 505 of the Dissolution Act added what is now subsection (d), which states, in pertinent part, as follows: “Each *** judgment [of child support] shall have the full force, effect[,] and attributes of any other judgment of this State, including the ability to be enforced.” 750 ILCS 5/505(d) (West Supp. 1999). Amended section 12 — 109 of the Code provides, in pertinent part, that “[e]very judgment arising by operation of law from a child support order shall bear interest as provided in [sjection 2 — 1303 commencing 30 days from the effective date of each such judgment.” 735 ILCS 5/12 — 109 (West 1998).
In Kaufman, 299 Ill. App. 3d at 509, 701 N.E.2d at 187, the appellant argued that interest on late payments under an order of maintenance was mandatory. Specifically, she contended that (1) the General Assembly enacted section 505(d) of the Dissolution Act in response to Finley, and that pursuant to that section, interest on a child support award is mandatory, and (2) Finley should not be applied to other dissolution judgments, such as orders to pay maintenance. Kaufman, 299 Ill. App. 3d at 509, 701 N.E.2d at 187. The appellate court disagreed and concluded that (1) section 505(d) of the Dissolution Act did not (a) address the question of interest or (b) apply to spousal maintenance awards; (2) not all civil judgments are subject to mandatory interest, therefore granting dissolution judgments the “full force and effect of law” does not mean that interest will automatically attach; and (3) the legislature did not intend to make interest mandatory on dissolution judgments. Kaufman, 299 Ill. App. 3d at 512, 701 N.E.2d at 189. The court further held that, pursuant to Finley, the “allowance of interest on all dissolution judgments is within the discretion of the trial court.” Kaufman, 299 Ill. App. 3d at 511, 701 N.E.2d at 188.
•4 In this case, the trial court’s reliance on Kaufman was misplaced. First, the Kaufman court addressed a question regarding maintenance; therefore, its analysis of section 505(d) of the Dissolution Act — a section expressly addressing child support — constitutes dicta. Moreover, because child support was not at issue in Kaufman, the court did not consider or apply section 12 — 109 of the Code, as amended in 1987, which unequivocally states that judgments of child support shall bear interest as provided in section 2 — 1303 of the Code (735 ILCS 5/2 — 1303 (West 1998)). 735 ILCS 5/12 — 109 (West 1998). Accordingly, we conclude that the trial court erred by determining that interest was discretionary, and Bonnie is entitled to interest on unpaid support accrued between June 1, 1987, and November 1994.
In so concluding, we note that In re Marriage of Steinberg, 302 Ill. App. 3d 845, 855-56, 706 N.E.2d 895, 902-03 (1998), does not require a different result. In that case, the respondent argued that the trial court erred by holding that interest on child support was mandatory under section 505(d) of the Dissolution Act. Steinberg, 302 Ill. App. 3d at 855, 706 N.E.2d at 902. The reviewing court agreed, citing both Finley and Kaufman. However, the parties did not raise and the Stein-berg court did not address section 12 — 109 of the Code in reaching its conclusion. Steinberg, 302 Ill. App. 3d at 855-56, 706 N.E.2d at 902-03.
III. CONCLUSION
For the reasons stated, we reverse the trial court’s judgment and remand for further proceedings consistent with the views expressed herein.
Reversed and remanded.
McCullough, j., concurs.