WI Court of Appeals – District III
Case Name: Susan Kay Quaranta v. Michael Palma Quaranta
Case No.: 2021AP000821
Officials: Hruz, Gill and Grogan, JJ.
Focus: Divorce – Maintenance Modification
Susan Quaranta appeals an order denying her motion to modify the amount and duration of Michael Quaranta’s obligations under a limited-term maintenance order. Susan argues that the circuit court erred by applying an improper legal standard that required the relevant substantial change in circumstances be unforeseeable. The appeals court opined that the circuit court never expressly stated that a change in circumstances must be unforeseeable in order to qualify as a substantial change in circumstances. The circuit court reasonably determined that Susan’s earning capacity and Michael’s increased income did not constitute a substantial change in circumstances since the divorce judgment, according to the appeals court.