In re Marriage of Zywiciel

In In re Marriage of Zywiciel (2000) 83 Cal.App.4th 1078, the wife moved for spousal support six years after entry of a dissolution decree that did not include any such support, based solely on the alleged great disparity in income between the parties. At the hearing, neither party testified, and the transcript consisted solely of a mechanical exchange among the lawyers and the judge, who simply plugged financial numbers into a DissoMaster computer program designed for calculating temporary spousal support. ( Id. at p. 1080.) Given the state of the record, the appellate court found itself "forced to agree" with the husband's contention that the award was "based on a figure generated by a computer program instead of the judge's weighing of the prescribed statutory factors." ( Id. at p. 1079.)