Section 26.14 Financial Needs of Spouse

• Library: Family Law Deskbook and 2014 Supp

a. (§26.14) Financial Needs of Spouse

The mere increase in a former spouse’s monthly income, standing alone, will not support an increase in an award of maintenance to the ex-spouse. Mitchell v. Mitchell, 610 S.W.2d 390 (Mo. App. E.D. 1980); In re Marriage of Mertz, 615 S.W.2d 627 (Mo. App. E.D. 1981); see also Orth v. Orth, 637 S.W.2d 201 (Mo. App. E.D. 1982). For example, in Welker v. Welker, 902 S.W.2d 865 (Mo. App. E.D. 1995), the court held that changes in a party’s financial circumstances or increases in the children’s needs are not exclusive examples of substantial and continuing changes that warrant a modification of a divorce decree. Nor does the increased “cost of living” by itself support an increase, but it is one factor that the...