In Gartside v. Gartside, 383 S.C. 35, 677 S.E. 2d 621 (Ct. App. S.C. 2009), the husband lost his $105,000 annual position with a yacht club. He testified that there were comparable jobs in the vicinity but none were available and that there were comparable jobs outside the "three county area" but he made no efforts to interview at those jobs.

He also testified that he had repeatedly relocated from Pennsylvania, Colorado, Georgia, and Texas prior to settling in South Carolina.

The court declined to impute income from the higher salary available elsewhere to the husband and lowered his maintenance payments to reflect the new reduced salary.

The court noted that the husband has established his career in the local community, put down roots, made friends, and should not be forced to "leave the environment he has known for 25 years" to seek employment outside the general community.