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According to Florida case law as of the date of this article, a substantial change of circumstances is defined as a change that is material, involuntary, permanent, and unanticipated at the entry of final judgment. Here, the court had a rehabilitative alimony plan in place which the court was able to monitor and make adjustments, as needed:

“Generally, alimony awards are subject to modification only when there is a substantial change of circumstances, defined as a change which is material, involuntary, permanent and unanticipated at entry of the final judgment. Zipperer v. Zipperer, 567 So.2d 916, 918 (Fla. 1st DCA 1990), rev. denied, 581 So.2d 1312 (Fla.1991); Penland v. Penland, 442 So.2d 1054, 1055 (Fla. 1st DCA 1983); Cowie v. Cowie, 564 So.2d 533, 535 n. 2 (Fla. 2d DCA 1990). A significant increase in a former wife’s needs since the dissolution will support an award of increased alimony. Zipperer, 567 So.2d at 918. Such an award may also be justified, in some cases, by a substantial rise in the financial ability of the paying spouse. Bedell v. Bedell, 583 So.2d 1005, 1007 (Fla.1991). In this case, however, we need not determine whether the trial court abused its discretion in characterizing the increase in the appellee’s needs as substantial, nor need we decide whether the appellant’s increased income was sufficient, under Bedell, to warrant the modification. Where, as here, the trial court has fashioned a complicated and lengthy rehabilitative plan fitted to the peculiar needs of the parties, the court is entitled to monitor the progress of that plan and make necessary adjustments to it whenever a party is able to show a material discrepancy between the rehabilitative progress the court anticipated and the degree of rehabilitation actually achieved by the recipient spouse. Naturally, the trial court enjoys much discretion in its monitoring and adjusting of rehabilitative plans and we will find an abuse of that discretion only where no reasonable person would take the view adopted by the court. Canakaris, 382 So.2d at 1203.”

See: Paulsen v. Paulsen – 603 So.2d 1317 (1992)




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