Belousoff v. McConnell CA2/5
Petitioner and appellant Melissa Belousoff appeals from a post-judgment order denying her request for modification of spousal support awarded to her former husband Monte McConnell. In the family law court, McConnell had the burden under Family Code section 4323 to show that cohabitation with his girlfriend did not reduce his need for spousal support. The family law court denied Belousoff’s request for modification after finding that McConnell and his girlfriend divided their contributions to household expenses under a written agreement in good faith, McConnell’s needs had not decreased, and McConnell had not suppressed a meaningful contribution from his cohabitant in order to show a continued need for support. On appeal, Belousoff contends that section 4323 requires the family law court to modify or terminate spousal support based on cohabitation, and McConnell failed to meet his burden because his evidence was not credible.
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