California, United States of America
The following excerpt is from GOLDMAN v. AMES STEPHEN GOLDMAN, B213863, No. PD034625 (Cal. App. 2010):
A trial court's order modifying a spousal support award is reviewed for abuse of discretion. (In re Marriage of Shaughnessy (2006) 139 Cal.App.4th 1225, 1235.) "We review the record to determine if the court's order is supported by substantial evidence and if a reasonable court could have made the order. If so, we will affirm. [Citation.]" (Mendoza v. Ramos (2010) 182 Cal.App.4th 680, 684 (Mendoza).)
A spousal support order "is modifiable only upon a material change of
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