Carlos v. Lane

Inexplicably, the majority finds a clear and express waiver of Carlos’ right to seek modification of alimony on the basis of Appellee’s voluntary cohabitation in a meretricious relationship, even though the settlement agreement specifies only another completely different ground. Furthermore, the majority opinion purports not to require “magic words,” but actually holds that a mere citation of the modification statute, without more, magically converts language of limited import into a general waiver of an ex-spouse’s right to modify *677alimony.

“The parties to a divorce agreement may waive the…