The moving party (former wife) brought a motion to change a 2013 final order for spousal support, seeking a retroactive and prospective increase, reinstatement of medical benefits, and additional life insurance/pension security.
She argued a material change in circumstances based on her increased medical needs and the payor's increased post-separation income.
The court found no compensatory basis to share in the payor's post-separation income increases and no evidence of increased medical expenses.
However, the court held that the eroding effect of inflation on the recipient's fixed income constituted a material change.
The court ordered the spousal support to be indexed annually to the Consumer Price Index, retroactive only to the date of effective notice in May 2019.
All other claims were dismissed.