In re the Marriage of Labuwi

Wife appeals the trial court’s post-judgment order that reduced both husband’s spousal support obligation to wife and wife’s child support obligation to husband. She argues that husband did not show an unanticipated substantial change of circumstances that would give the trial court the authority to make those modifications. We agree and reverse.

The parties’ marriage was dissolved in September 1995. The trial court incorporated into the dissolution judgment an extensive Marital Settlement Agreement that the parties had negotiated with the assistance of an independent mediator. In accordance…