When and How Can Spousal Maintenance Be Changed in Minnesota?

Life after divorce isn’t static—people change jobs, inherit money, develop health conditions, or face rising living costs. These changes sometimes make a previous spousal maintenance order feel unfair or unworkable. But in Minnesota, modifying that order isn’t just a matter of asking for more or less. It involves meeting legal standards that balance personal change with judicial consistency.

Let’s explore how courts handle spousal maintenance modifications, and what real cases reveal about when and how a judge might say yes—or no—to a request for change.

The Starting Point: What the Law Actually Says

Under Minn. Stat. § 518A.39 (2024), a spousal maintenance order can be modified if there’s been a “substantial change in circumstances” that makes the original order unreasonable or unfair. These changes often involve:

• A significant increase or decrease in income
• A change in living expenses or personal needs
• Unexpected life events such as health problems or job loss

But while the statute provides this opening, Minnesota courts apply the rule conservatively. The law favors stability in support orders and expects parties to have anticipated ordinary life changes at the time of the divorce.

“Not a Lifetime Profit-Sharing Plan”: Snyder v. Snyder

This principle was underscored in one of Minnesota’s foundational cases, Snyder v. Snyder, where the Minnesota Supreme Court rejected the idea that an ex-spouse should automatically benefit from their former partner’s financial success.

The Court famously stated: “Spousal maintenance is not a lifetime profit-sharing plan.” (212 N.W.2d 869, 872 (Minn. 1973)).

When Rachel* Snyder sought an increase in maintenance after her former husband received a promotion, the Court ruled that his higher income, by itself, wasn’t a justification for increasing her support. The court’s focus remained on her actual needs and whether those needs had changed—not on his improving lifestyle.

Keeping Lifestyle in Check: Beck v. Kaplan

In a similar vein, the Minnesota Supreme Court reiterated in Beck v. Kaplan that maintenance awards should not raise a spouse’s standard of living above what they enjoyed during the marriage.

The Court held: “Where maintenance is initially awarded to meet the recipient’s needs consistent with the marital standard of living, the obligee is not entitled to a higher standard simply because the obligor’s income increases.” (566 N.W.2d 723, 726 (Minn. 1997)).

For Dana* Beck, this meant that although her ex-husband had seen significant financial growth, her maintenance would not be raised to reflect his gains unless she could show that her needs—defined by the marital standard—had actually increased.

No Reward for Overspending: Maeder v. Maeder

Another challenge arises when the spouse receiving maintenance overspends or mismanages their resources. That’s what happened in Maeder v. Maeder, where the obligee had dissipated assets and accumulated new debts.

The court acknowledged that, while such conduct doesn’t typically justify an increase in maintenance, “a court may still continue support to prevent a spouse from becoming financially destitute or reliant on public assistance.” (480 N.W.2d 677, 680 (Minn. Ct. App. 1992)).

In short, courts may distinguish between self-inflicted hardship and a real need for ongoing support, especially when the alternative would shift the burden to the state.

What About Genuine Decreases in Need?

Although rare, some cases involve a legitimate reduction in the receiving spouse’s need for support. This could happen due to:

• Receiving an inheritance
• Securing more stable or higher-paying employment
• Moving to a more affordable living arrangement
• Beginning to collect Social Security or pension income

These changes often support a downward modification or even termination of maintenance. However, courts will evaluate not just the amount of new income or assets, but also whether the overall needs of the spouse remain unmet.

What This Means for Your Case

If you’re seeking to modify spousal maintenance in Minnesota, you need to demonstrate:

• A substantial change in financial circumstances
• That the change wasn’t anticipated at the time of the original order
• That the change makes the current support order unreasonable or unfair

On the other hand, if you’re opposing a modification, you’ll want to show that:

• The change in circumstances is minor or temporary
• The existing order continues to meet both parties’ needs within reason
• The underlying assumptions of the divorce decree still apply

Minnesota courts walk a careful line between respecting finality and allowing flexibility. A well-supported modification request can succeed—but only when it clearly aligns with statutory standards and proven need.

📚 Citations:

• Minn. Stat. § 518A.39 (2024). – (Authorizes spousal maintenance modification upon a substantial change in circumstances making the original order unreasonable or unfair.)
• Snyder v. Snyder, 212 N.W.2d 869, 872 (Minn. 1973). – (“Spousal maintenance is not a lifetime profit-sharing plan.”)
• Beck v. Kaplan, 566 N.W.2d 723, 726 (Minn. 1997). – (A maintenance award should not raise the recipient’s standard of living beyond the marital standard simply due to an obligor’s increased income.)
• Maeder v. Maeder, 480 N.W.2d 677, 680 (Minn. Ct. App. 1992). – (Support may continue to prevent destitution even if hardship stems from poor financial decisions.)
• Joneja v. Joneja, 422 N.W.2d 306 (Minn. Ct. App. 1988). – (An increase in the paying spouse’s income alone does not justify an increase in maintenance.)

*The identities of these parties and facts of their matter were publicly published and thus not confidential. While the case holding and statutory references are accurate, creative liberty has been imposed for the emotional portrayal of the parties.