Cunningham v. Cunningham

While I agree with the majority’s ultimate conclusions, I find the opinion clouding even further the apparent distinction between *441“dependent spouse” and “dependency.” The majority’s reliance on Rowe v. Rowe, 305 N.C. 177, 287 S.E.2d 840 (1982), concludes “that defendant’s status as the dependent spouse is not properly reconsidered upon a motion to modify ....” As such, the opinion seems to say that dependency in the context of the amount of alimony to be paid can be considered upon a motion to modify, but the dependent status cannot. Such a distinction does not appear to make any sense to me,…