In re the Marriage of Hulscher

¶1 Janice Hulscher appeals from the trial court’s order modifying her spousal support award, *710arguing the spousal support provision is nonmodifiable by its terms. When parties include a nonmodifable spousal maintenance provision in a separation contract, generally our courts may not modify spousal maintenance unless the provision was unfair when entered. We hold that parties need not enter a separate written instrument constituting their separation contract, so long as the decree of dissolution embodies the agreed-to separation contract provisions. Accordingly, we hold that the trial court…