[32] It would seem to me that the message of Johannes v. Johannes is that a one-year principle, rule, guideline or rule of thumb, whatever it may be called, only has relevance to the extent that the reasoning on which it is based is applicable in any particular case. It has no significance whatever, whether applied to arrears of spousal or child support, as a rule having any force of its own. Its usefulness is rather to alert one to the possibility that, in cases where arrears have accumulated beyond one year, circumstances may exist that are themselves relevant by the terms of the applicable statute and that bear upon the issue before the court. For example, the failure on the part of a spouse to enforce a support order for a period lasting in excess of one year may be considered upon a variation application relevant evidence as to lack of need. It is, however, the matter of need that is the relevant consideration, not the failure to enforce, per se.
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