Richard P. Gabriel v. Diana K. Gabriel

Summary

The court held that the plaintiff could not be held in contempt for unilaterally reducing the combined alimony and support payments because a statutory custody transfer automatically suspended the child-support component, leaving no sufficiently clear order requiring a specific payment. The court nevertheless held that the trial court improperly modified the unallocated award without determining the original child-support component and applying the child-support guidelines. It also held that the parties' agreement barred consideration of the defendant's cohabitation, including financial effects resulting from it, in determining alimony. The judgment was therefore reversed in part and affirmed in part, with further proceedings ordered.