In re Marriage of Andreen

In In re Marriage of Andreen (1978) 76 Cal.App.3d 667, the court was faced with a decree that would, one year later (i.e., in 1979), reduce support to $ 1 per month. While declining to overturn that provision at that time (i.e., 1978), the court expressly held that, when 1979 arrived, the wife could, then, properly seek modification on the ground that the original anticipation (similar to the one herein involved) that the wife would be self-supporting by 1979 had not turned out to be correct. The Andreen court said (at p. 673): "The automatic reduction was based upon the trial court's assumption that by November 1979 wife would be earning enough to afford a standard of living appropriate to the parties' social and cultural condition. The failure of that assumption would constitute a change of condition and provide a ground for modification of this phase of the decree. It is much more realistic (and at least as fair) to appraise the parties' 1979 situation by the measure of actual rather than prophesied 1979 facts."