In re the Marriage of Marshall

I agree with Division I of the majority opinion; the district court had jurisdiction to act on the application for modification. I do not agree, however, that a court has authority to modify a provision for fixed-term alimony.

The majority finds authority to modify the award in Iowa Code section 598.21(8) (1985) which provides, in relevant part, that “[t]he court may subsequently modify orders made under this section when there is a substantial change in circumstances.” I submit this is not a grant of new authority at all; for well over 100 years our Code has provided for modification under…