The Appellate Group

Thayne v. Thayne

Thayne v. Thayne, 2022 UT App 122 (Bench, J.)


In their divorce decree, the parties agreed that ex-wife would receive $840 a month in alimony, that ex-wife would make reasonable efforts to seek employment within four years, and contemplated that ex-husband’s salary would decrease from $140,000 a year to somewhere between $90,000–100,000 per year. Three months later, ex-wife was employed, and ex-husband filed a motion to modify the judgment based on “substantial and material change in circumstances.” The district court granted ex-wife’s motion to dismiss his petition to modify child and spousal support. On Appeal, The Utah Court of Appeals affirmed, holding:

  • The district court did not err when it concluded that the changes in circumstances were already addressed by the original judgment.

Read the full court opinion