In Re Marriage of Kowski

Thaddeus Kowski (respondent) appeals from an order of the circuit court of Cook County which denied his petition to reduce maintenance obligations to Anna Kowski (petitioner). The trial court denied the petition on the grounds that a substantial change had not occurred in respondent’s circumstances, in that he had voluntarily obtained a new employment without first attempting to find a position that would duplicate the earnings of his previous employment. The sole question presented for our review is whether respondent’s failure to attempt to duplicate his earnings before voluntarily changing…