In re the Marriage of Spreen

When Marie and Alan Spreen divorced in 1995, the trial court awarded Marie maintenance of $1,400 per month for four years. In late 1998, Marie petitioned for an extension and increase of maintenance based on a change in circumstances—her worsened mental health—that made her unemployable. The trial court extended maintenance, implicitly finding that there was a change in circumstances. But the court limited the maintenance to one additional year, finding that Marie had received maintenance “long enough” and that government assistance is available to people unable to work because of medical…