In re Patterson

*9Husband appeals supplemental judgments granting his motion to modify spousal support and awarding attorney fees and costs to wife. The trial court concluded that, because wife received an economic benefit from staying in her partner's house in Yachats, her use of that property constituted "a substantial change in economic circumstance," ORS 107.135(3)(a),1 justifying a $225 monthly reduction in wife's spousal support. However, the court awarded attorney fees and costs to wife due to deficiencies in husband's case that had unnecessarily prolonged the modification proceedings. On appeal,…