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Domestic Relations – Spousal Support – Change In Circumstance

The Court of Appeals says a divorce court erred in ruling that a consent decree incorporating an agreement between wife and husband qualified as a “stipulation or contract” under Va. Code § 20-109(C), and husband’s spousal support obligation remained modifiable for a change in circumstance.
Brown v. Brown (Va.Ct.App.) (VLW 009-7-157) (7 pp.)

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