Supreme Court of Alabama

Ex Parte Randolph G. Wilson, Jr. (in Re: Randolph G. Wilson, Jr. v. Teresa L. Wilson)

January 16, 2018262 So. 3d 1202

Summary

The Court held that a petition to modify periodic alimony must be evaluated by measuring material changes in the parties' circumstances from the date alimony was originally awarded or last modified, rather than only from the date of the most recent judgment denying modification. It rejected the contrary approach adopted by the Court of Civil Appeals because it could produce inequitable results and prevent consideration of cumulative changes. The judgment was reversed and remanded for further proceedings under the correct baseline.