In re Marriage of Dea

Court did not abuse its discretion in denying motion of husband, who is disabled, has MS, and receives social security benefits, to modify maintenance amount he receives from wife. Husband did not offer any evidence showing that his MS had progressed in a way that was not anticipated in the dissolution judgment. Record reflects that his social security benefits have increased over the last 5 years.Court recognized, in dissolution judgment, that wife's earning potential was likely to increase, and court factored that into its maintenance award. An increase in the paying party's income is generally not sufficient, on its own, to warrant modification of maintenance. (MIKVA and HARRIS, concurring.)