Former husband was not entitled to a credit toward his maintenance obligation for social security benefits received by his former wife by virtue of contributions made by the husband.  In re Schrimpf
___Defined
 The word “alimony” in former section 18 of the Divorce Act (see now this section), is synonymous with the word “maintenance” used in subsection (a) of this section.  Pierce v. Pierce
___Employment Secured
 Even though respondent had obtained employment, the court properly continued maintenance, since she did not have her own pension and would never earn as much as petitioner.  In re Connors
___Equitable
 Just as the court is without authority, after a husband’s death, to award maintenance to the wife, it is without authority, after the husband’s death, to award equitable maintenance pending appeal.  Stacke. V. Bates
___Grant Held Erroneous
 Grant of permanent alimony to wife in addition to husband’s interest in the marital residence was held erroneous.  Demos v. Demos
___In Gross
 Subsection (c) of this section does not authorize the court to award maintenance in gross after the death of the payor spouse.  Stacke v. Bates
___Job Search
 Extension of maintenance constituted an abuse of discretion in light of the court’s finding that respondent’s job searching efforts were insufficient.  In re Koenigsknecht
___Standard
 The discretionary standard for modification of maintenance found in subsection (a) of this section is essentially unchanged from its applications under the former Divorce Act.  In re McGowan
___Need of Support
 A shown need for support cannot be controlling and in itself sufficient to defeat a petition to terminate maintenance when all other factors demonstrate an ongoing, conjugal relationship to exist.  In re Frasco
___Paramour
 A divorced spouse should not be required to support the other spouse’s paramour.  Hall v. Hall

Divorce Lawyers New York

 A property settlement agreement which stated that “it is agreed that the payment as heretofore provided of alimony in the amount, of $550 per month will in no way be effected or amended because of an increase in income to either party,” did not divest the court of its power to modify its decree under former section 18 of the Divorce Act *see now this section), but simply precluded consideration of income in determining whether a change in circumstances had occurred and, such a limiting provision could not be against public settlement in lieu of alimony, the parties could have eliminated alimony completely and permanently from the court’s consideration.  Pollard v. Pollard
 There was a sufficient showing of change of circumstance to warrant to modification of the amount of payments.  Juen v. Juen
 The trial court, which conducted a long hearing, had ample justification to conclude from the evidence, that there was a change in circumstances such as would justify a modification of the divorce decree reducing the weekly child support payments.  Lewis v. Lewis
 

 An award of permanent maintenance in a dissolution proceeding containing no provision for modification review was deemed an abuse of discretion by the trial judge.  In re Girrulat
 Where an agreement characterized the maintenance as “permanent,” this term may also be used simply to distinguish permanent maintenance from temporary maintenance awarded during the pendency of a dissolution action; such as when the agreement was too vague to establish that the parties intended to contravene the general policy of Illinois and provide for continuing maintenance payments after the former wife’s remarriage.  In re Jensen
 There is no language in this section which prohibits modification of a permanent maintenance award, and such awards are therefore modifiable.  In re Arvin

 Maintenance agreements may be modified or terminated under circumstances stated in statutory provisions, unless the parties’ intent is clearly manifested in such agreement to limit or preclude such judicial modification or termination.  In re Scott
 If the language of the agreement does not expressly preclude or limit modification of its terms, it is error to hold the maintenance non-modifiable.  In re Scott
 The parties may agree that reductions or termination of maintenance can only occur under specific circumstances, regardless of “good faith”, and that their agreement controls.  In re Mateja
 The mandate of this section, as it applies to future maintenance, cannot be avoided by agreement between the parties.  Ihle v. Ihle
 The only limitations placed on the parties’ freedom to fashion their own property and maintenance agreements are that the end product to be incorporated into the divorce decree may not be so unjust as to be unconscionable and the obligation to pay future maintenance is terminated upon the death of either party, or the remarriage of the party receiving maintenance, or if the party receiving maintenance cohabits with another person on a resident, continuing conjugal basis.  Simmons v. Simmons

 The recipient of maintenance is under an affirmative obligation to seek appropriate training and skills to become financially independent in the future; the failure to make good faith efforts to pendent in the future; the failure to make good faith efforts to achieve this goal, following a reasonable time frame during which the objective should be accomplished, might form the basis for a petition for modification pursuant to subsection (a) of this section.  In re Martin

 Where the court found husband was able to make payment to wife but had chosen to spend his money in other ways, the trial court’s determination that husband’s failure to pay was willful certainly was not against the manifest weight of the evidence; the trial court did not abuse its discretion in finding husband in contempt and sentencing him to 30 days in jail.  In re Dunseth
 The power of a court to enforce payment for child support by contempt is limited to cases of willful and contumacious refusal to obey, the order of the court.  In re Lavelle
 Where the record supported the husband’s contention that his non-payment was due to a lack of sufficient income respondent’s failure to maintain health insurance or his failure to pay medical expenses not covered by insurance was willful and contumacious.  In re Lavelle
 While it was true that the husband did not make his payments through the clerk’s office, the court found that the parties had a mutual agreement whereby respondent would make the payments directly to petitioner, the husband’s failure to make payment through the clerk’s office did not constitute contempt when petitioner at the least acquiesced in such method of payment if not encouraged payment directly to her.  In re Lavelle
 Where petitioner reduced his maintenance and support payments without authorization from the court, and failed to satisfactorily establish that his failure to pay was due to his financial inability to pay, the judgment finding petitioner in contempt of court was affirmed.  In re Eisentstein
 Mere absence of compliance with the provisions of the decree is not sufficient basis for a judgment of contempt of court unless the evidence shows the failure to comply was a willful and contumacious refusal to obey the court order.  Giamanco v. Giamanco
  A court should have considered the defendant’s financial condition at the time of the contempt hearing to determine whether his failure to pay was willful and contumacious.  Giamanco v. Giamanco

 Trial court abused its discretion in modifying respondent’s obligation to provide that respondent did not have any obligation to pay for the college expenses of his son, which obligation was conditioned on his son being college material and on respondent’s financial ability to provide for the expenses, because in order to make an intelligent and useful decision, there would have to be facts to indicate whether respondent’s son was college material, what his expenses would be, and respondent’s financial ability at that time to provide for the expenses; at the time respondent brought his petition, none of these things could be ascertained.  In re Walters

   Where parties expressly provided in clear and unequivocal language for maintenance and for its termination upon the occurrence of either of two conditions, the death or the remarriage of the respondent, the execution of this agreement, voluntarily signed by both parties who were each represented by counsel, constituted a clear, unequivocal, and decisive act from which it may be inferred that petitioner waived conjugal cohabitation as a condition for the termination of maintenance.  In re Giles   The omission of conjugal cohabitation as a condition for termination in a maintenance agreement indicates that the parties did not intend to have this statutory condition apply.  In re Arvin

 Where there was no evidence of a sexual relationship, no evidence of sharing expenses, no evidence of the alleged cohabitant paying any of respondent’s expenses the evidence was insufficient paying any of respondent’s expenses the evidence was insufficient evidence to warrant to termination of maintenance.  In re Johnson.
 The fact that wife’s relationship was terminated before hearing and lasted only approximately six months weighed against finding a conjugal relationship.  In re Caradonna
 Where the nature of an ex-wife’s employment as a full-time housekeeper and nurse required she live in her employer’s house, and there was no indication that either she or her employer considered themselves to have a husband-wife relationship, the ex-wife’s relationship with the employer did not justify termination of all support on the basis of cohabitation.  In re Nolen
  There was ample support for the view that plaintiff’s need for support had not been materially affected and that defendant has failed to sustain his burden of establishing that plaintiff was involved in a de facto husband-wife relationship with her landlord; accordingly, the trial court’s finding that plaintiff was not cohabiting with another person on a resident, continuing and conjugal basis was not against the manifest weight of the evidence.  In re Reeder

 Where the wife’s paramour bought groceries for her and her children and bought some clothing for her, he took his meals with her and her children, he worked with her to clean and maintain their residence, she did his laundry and cooked his meals, he moved into her residence in October and left in January, and after moving out, phoned weekly, Christmas gifts to her children were signed “Larry and Mom”, said she spent the holidays at his parents’ home, the evidence was insufficient to establish cohabitation on a continuing basis.  In re Clark

___Effect
 The trial court’s assertion that “[o]nce you live with a man, you have voided your chance to get alimony,” was an overbroad and erroneous interpretation of legislative intent.  In re Bramson

___Evidence Insufficient
 The trial court’s decision not to terminate maintenance was not against the manifest weight of the evidence where trial court considered the short period of cohabitation, the continuing need for support, the lack of commingling of funds, the petitioner’s payment of all her bills with the exception of rent and utilities, and the termination so of the relationship, and ruled that there was no de facto relationship.  In re Liming
 The trial court’s finding that the relationship implied more of a dating relationship and not a de facto marriage was not against the manifest weight of the evidence, where the former wife and her friend dated other people as well as each other, took trips separately as well as together, maintained separate residences, and did not commingle assets.  Rosche v. Rosche
 The evidence fell short of establishing a husband-wife relationship where both the wife and her boyfriend dated other people, her boyfriend considered her arrangement as rooming with a friend on a temporary basis until she rejoined her children, she moved in, in part, to provide more room for visitation with her children, she retained her name, received mail at more than one address and had identification cards listing several addresses, and additionally, there was no evidence that the two commingled their funds, as might be expected in a husband-wife relationship.  In re Bramson