Wessels v. Wessels

After a 21-year marriage in which Yvonne (plaintiff) supported the family as James (defendant) finished medical school and then became a homemaker while he practiced, the couple divorced and stipulated to five years of rehabilitative alimony conditioned on Yvonne making every effort toward self-sufficiency. Yvonne developed post-traumatic stress disorder and major depression that prevented her from maintaining employment despite genuine attempts, and just before the alimony was set to expire, she petitioned to extend or convert it to permanent alimony; the trial court granted permanent alimony based on unforeseen changed circumstances, and James appealed, arguing rehabilitative alimony cannot legally be converted to permanent alimony.

Whether a court may convert a rehabilitative-alimony award into a permanent-alimony award based on unforeseen changed circumstances arising after the original decree.