On a motion to change spousal support arising from a 26-year common law relationship, the moving party sought termination or reduction of indefinite support on the basis that the recipient had failed to make reasonable efforts toward self-sufficiency.
The court found a material change because the recipient admitted he was capable of work and had not made reasonable efforts to obtain employment, and it imputed income of $30,000 to him.
However, applying compensatory and non-compensatory support principles for a long traditional relationship, together with the Spousal Support Advisory Guidelines, the court held the recipient remained entitled to indefinite support and that the existing monthly payment was already below the guideline range.
The motion succeeded only to the extent of the finding of material change and imputation of income, but no reduction, step-down, termination, or review was ordered.
