If Standard of Living is Not Calculated at the Time of the Divorce, Courts Have to Calculate it Before Deciding a Modification Request – Who Knew?

Trial courts deny modification requests all of the time for a whole myriad of reasons and quite often, the decision is affirmed even when it appears that the moving party has a made a prima facie (initial) showing of changed circumstances. After all, in the Cardalli case and others, the Supreme Court and the Appellate Division held that the bar to show changed circumstances is not a high one. But in Prendergast v.