Marriage T.C. v. District Columbia

*452 *421 D.C. (Husband) appeals from an order granting a petition for modification of spousal support filed by his former spouse T.C. (Wife). 1 The trial court found that a significant increase in Wife's earnings since the last spousal support order amounted to "changed circumstances" and on that basis reduced her support payments to Husband. Husband makes several arguments in support of his appeal, including that: the parties' reasonable expectations as expressed in their dissolution agreements contemplated that an increase in Wife's salary would not constitute changed circumstances; the parties intended there would be no cap on additional spousal support irrespective of Wife's earnings; the court improperly found the spousal support provisions ambiguous; and the court's Family Code section 4320 analysis was flawed because it mistakenly treated Husband's income as taxable at the time of separation.

As a threshold matter, we conclude substantial evidence supports the trial court's finding of changed circumstances sufficient to justify reduction of the additional spousal support paid by Wife. But the court erred when, in fashioning the specific modification, it failed to…