Ruth Cohen v. Franklin Cohen

Summary

The court affirmed the modification of the alimony order because the trial court properly determined that changed financial circumstances had made the prior modification insufficient to fulfill the original award's purpose. Although the trial court may have used an incorrect comparison at the threshold stage, that error was harmless because the later modification was based on the substantial increase in the defendant's income since the 2012 order. The court also held that the plaintiff's motion was legally sufficient, that extrinsic evidence and court-file materials could be considered to determine the original award's purpose, and that the resulting percentage-based alimony order was permissible.