## Facts

- After a 23+ year marriage, the parties’ marriage was dissolved in 1988.
- At dissolution, the husband earned about $4,700/month net disposable income; the wife earned about $1,900/month and worked as a nurse.
- The dissolution judgment ordered the husband to pay $739/month in spousal support.
- In 1991, the husband voluntarily resigned a well-paid sales executive job, joined a Catholic religious order, and entered a monastery for religious formation and unpaid community work.
- He anticipated no earned income for several years and planned to support himself from separate-property savings.
- The husband sought modification and termination of spousal support based on his lack of earned income.
- The husband continued voluntarily paying substantial amounts toward the parties’ adult daughters’ college-related expenses.
- The trial court found the husband left employment in good faith and found the wife capable of self-support; it reduced spousal support to zero.
- The wife appealed the zero-support modification order.

## Issues

1. Whether the trial court abused its discretion by reducing spousal support to zero when the supporting spouse’s reduced ability to pay resulted from a voluntary, good-faith decision to leave lucrative employment for religious life.
2. Whether, under the circumstances, the supported spouse’s earning capacity and self-sufficiency justified termination of ongoing support.

## Decision

- The Court of Appeal affirmed the order reducing spousal support to zero.
- The trial court could credit the husband’s good-faith career and lifestyle change and decline to impute prior earnings absent a finding of bad-faith avoidance of support.
- The supported spouse’s demonstrated ability to be financially independent supported termination of support.
- On deferential review, the modification order was within the trial court’s broad discretion.

## Legal Principles

- Modification of spousal support is committed to the trial court’s broad discretion and is reviewed for abuse of discretion.
- A supporting spouse’s voluntary reduction of income does not automatically bar modification; the court may consider whether the change was made in good faith or to evade support.
- If a supporting spouse reduces income in bad faith, a court may rely on earning capacity rather than actual income.
- A supporting spouse’s good-faith religious or vocational choice may be considered as part of the total circumstances affecting ability to pay.
- The supported spouse’s need and ability to become self-supporting are central to whether support should continue, be reduced, or be terminated.

## Conclusion

The court upheld termination of spousal support because the husband’s decision to enter religious life was found to be made in good faith rather than to avoid support, and the wife’s earning capacity supported the trial court’s determination that ongoing support was no longer equitable.


In re Marriage of Meegan, 11 Cal. App. 4th 156, 13 Cal. Rptr. 2d 799 (Ct. App. 1992)