Marriage of T.C. and D.C.Annotate this Case
D.C. (Husband) appealed an order granting a petition for modification of spousal support filed by his former spouse T.C. (Wife). The trial court found that a significant increase in Wife's earnings since the last spousal support order amounted to "changed circumstances," and on that basis reduced her support payments to Husband. Husband argued on appeal: (1) the parties' reasonable expectations as expressed in their dissolution agreements contemplated that an increase in Wife's salary would not constitute changed circumstances; (2) the parties intended there would be no cap on additional spousal support irrespective of Wife's earnings; (3) the court improperly found the spousal support provisions ambiguous; and (4) the court's Family Code section 4320 analysis was flawed because it mistakenly treated Husband's income as taxable at the time of separation. The Court of Appeal found substantial evidence supported the trial court's finding of changed circumstances sufficient to justify reduction of the additional spousal support paid by Wife. However, the Court found the trial court erred when fashioning the specific modification, it failed to consider the parties' reasonable expectations as expressed in their dissolution agreement that Wife's earnings would continue to increase. The Court therefore reversed and remanded for modification of Wife's spousal support obligations for further consideration.