Section 10.73 Generally

• Library: Family Law (2019 Supp)

1. (§10.73) Generally

Add the following text at the end of the second full paragraph on page 350 of the original chapter:

In McHugh v. Slomka, 531 S.W.3d 588 (Mo. App. E.D. 2017), the Eastern District found that the trial court erred when it did not uphold the parties’ original judgment, which included a provision of the settlement that, if circumstances changed in a particular way, the spousal support may be modified.

Add the following text after the cite to Shanks v. Shanks at the end of the third paragraph on page 350 of the original chapter:

In Almuttar v. Almuttar, 479 S.W.3d 135 (Mo. App. W.D. 2016), the court held that a failure to make reasonable efforts to become self-supporting is a significant change in circumstances sufficient to modify an award of spousal support. Further, in Layden v. Layden, 514 S.W.3d 667 (Mo. App. E.D. 2017), the court found a voluntary reduction in income when the...