In re Marriage of Golden

I respectfully dissent. In my opinion, the majority’s characterization of the issues in this case allows respondent to fortuitously avoid his burden of proof by simply including the word “review” in the title of his petition. By hinging its analysis on whether “review proceedings” are different from “modification proceedings,” the majority proceeds to carve out its own version of a “review hearing,” in which maintenance can be modified or even terminated absent a showing of a substantial change in circumstances. Such a result flies in the face of the legislature’s mandate that “an order for…