Betty Brown v. Melvin Brown
Betty R. Brown divorced Melvin E. Brown after twenty-five years, with the trial court awarding her alimony. Eight years later, Melvin petitioned to terminate his alimony obligation, citing Betty's increased earnings. The trial court denied this petition, finding Betty still economically disadvantaged and retaining her alimony as a "safety net," also ordering Melvin to cover her attorney fees. The Court of Appeals affirmed the trial court's decision. It ruled that a material change in circumstances must be unforeseeable and that despite Betty earning more than Melvin, she still faced a relative economic disadvantage due to ongoing mortgage payments and past financial struggles.