In re the Marriage of Bates

This case presents the issue of what analysis should be applied in determining the effect of the remarriage of a supported spouse on a previous award of spousal support.1

The case involves the modification of a dissolution decree in which the trial court originally awarded wife $600 per month and 10 percent of her husband’s employment bonuses as permanent spousal support.2 Several months later, wife remarried and husband moved to modify the decree to eliminate the award of spousal support. The trial court eliminated the bonus provision but retained the $600 per month part of the original…