Financial Independence for the Former Wife
Where former wife had completed the necessary training and received certification as a respiratory therapist and had begun making inquiries into available employment opportunities when she was involved in an automobile accident, injuring her back, the trial court was not required to compel her to actively seek employment when she would be unable to fulfill the job requirements. In re Hucker
A spouse who receives maintenance is under an affirmative obligation to seek appropriate training and skills in order to reach the goal of becoming financially independent; a failure to make good faith efforts toward this goal, following a reasonable time frame during which this objective should have been accomplished, may be grounds for modification of maintenance. In re Hucker
Where one spouse was found to be in good health at the time the judgment of dissolution was entered, and the record five years later did not reflect a substantial or extraordinary change in that spouse’s circumstances, but revealed that the other spouse had suffered a heart attack and remained hospitalized in a coma for a period of time, and nothing indicated that the spouse seeking maintenance was completely handicapped or suffered from any terminal illness or other physical impairment absent a showing of extraordinary circumstances, that spouse still had a continuing duty to become financially independent. In re Jones
