Opinion
WD 57621
Opinion Filed: October 17, 2000
APPEAL FROM THE CIRCUIT COURT OF BOONE COUNTY, HONORABLE JOSEPH D. HOLT, JUDGE.
Pamela Lambert, Columbia for appellant
Edward Christian Clausen, Jefferson City for respondent
Before Presiding Judge Harold L. Lowenstein, Judge Laura Denvir Stith and Judge Thomas H. Newton.
Appellant Betty Lee Bradley appeals the trial court's judgment denying her motion to modify the amount of maintenance that Respondent William Bradley was ordered to pay her under the terms of a dissolution decree entered on November 25, 1981. The issues before us are whether the trial court erred: (1) in failing to find a substantial and continuing change in circumstances from the time of the original dissolution decree; in that Mrs. Bradley, who was working at the time of the dissolution, is now disabled, unable to work, and drawing social security, and her expenses exceed her income by $1,005 per month; and (2) in ruling that in determining whether a substantial change in circumstances had occurred which rendered the terms of the original decree unreasonable, it would ignore the effects of 18 years of inflation and would ignore any changes which could have been foreseen at the time of the dissolution, without any evidence that they were in fact considered at the time of the original decree.
We find these rulings were erroneous. The court should have considered the effects of Mrs. Bradley's disability on her earning capacity, as well as the fact that her disability caused a reduction in her income by one-seventh in real terms, and by much more if the effects of 18 years of inflation are considered, as they should have been. The court similarly erred in refusing to consider expenses which were proved but which it believed the parties should have considered and taken into account 18 years earlier, and erred in failing to consider whether these changes were so substantial as to render the terms of the original decree unreasonable. Accordingly, we reverse and remand for further proceedings in accordance with this opinion.
FACTUAL AND PROCEDURAL BACKGROUND
The twenty-five year marriage of Betty Lee Bradley and William Bradley was dissolved by order of the Circuit Court of Saint Louis County, Missouri, entered November 25, 1981. At the time of dissolution, Mr. Bradley, then 47 years old, was earning approximately $7,600 per month as a medical doctor. Although Mrs. Bradley, then 44 years old, was primarily a mother and homemaker, she was earning $825 per month. This amount included $300 she had earned monthly doing "some bookwork" in Mr. Bradley's medical office.
The decree was based on and incorporated a Stipulation and Property Settlement Agreement. In accordance with that Agreement, the decree provided that Mrs. Bradley was to receive the parties' new, paid-for Lincoln automobile. She was given primary physical custody of the parties' three teenage sons and received $900 per month in child support for them. She was also awarded the family home, which had been remodeled in part and had a nearly new roof at the time of the dissolution. Mr. Bradley was directed to pay the mortgage on the house as a form of maintenance. The court also ordered him to pay Mrs. Bradley statutory maintenance of $1,000 per month, and, as additional maintenance, to pay the taxes and insurance on the home for five years. Presumably, the parties anticipated that by that point Mrs. Bradley would be earning enough to take upon herself the payment of insurance and taxes on the house. The dissolution decree provided that the amount of maintenance "shall be subject to modification by the Court upon a showing by either party of a changed circumstances so substantial and continuing as to make the terms [of the original maintenance order] unreasonable as provided in Section 452.370 . . ."
Mrs. Bradley did not work immediately after the dissolution, but within a few years she began work as a clerk in a flower shop, performing miscellaneous duties and earning approximately $500 per month. In 1988, Mrs. Bradley took a factory job in Centralia, Missouri, with A.B. Chance, Inc. She worked full time and generally accrued 6 hours per week in overtime as well, earning approximately $1,500 to $2,000 per month.
After the dissolution, Mrs. Bradley engaged in excessive drinking, arising in part out of depression. She was diagnosed with cirrhosis of the liver in January, 1994. Mr. Bradley presented evidence that it was at least in part as a result of Mrs. Bradley's drinking and her resulting health problems that, in the Spring of 1995, she was terminated from her job with A.B. Chance due to excessive absences. Mrs. Bradley presented evidence that her health problems, whatever their origin, in fact prevented her from obtaining another job, and that as a result she had been forced to apply for Social Security Disability benefits. On September 25, 1996, the Social Security Administration awarded benefits to Mrs. Bradley. In so doing, the Administrative Law Judge [ALJ] found that Mrs. Bradley suffered from "impairments which are considered to be severe under the Social Security Act and Regulations: [including] liver cirrhosis; chronic hepatitis; ascites; anasarca; clotting abnormalities; gastritis; and pruritis." The ALJ further found that:
[t]hese impairments prevent the claimant from engaging in any type of even moderately strenuous activity, including stretching, bending, stooping, pushing and pulling things, lifting and carrying items weighing over ten pounds, ascending more than two flights of stairs, walking farther than three blocks, standing in excess of thirty minutes, and from engaging in activity requiring sustained concentration.
The ALJ additionally noted that "[g]iven the claimant's residual functional capacity, age, education and past relevant work experience, there have been no jobs existing in significant numbers that the claimant has been capable of performing since May 1, 1995. . . . The claimant has been under a disability, as defined by the Social Security Act, since May 1, 1995."
After nearly two years of alcohol abuse, Mrs. Bradley quit drinking, and began extensive and extended treatment with Dr. Elizabeth Armstrong, M.D., for cirrhosis of the liver, depression, anxiety, and edema, an allergic reaction from exposure to toxic chemicals. The doctor later testified that she was unable, during a period in 1995, to administer some necessary tests to monitor Mrs. Bradley's complications arising from her cirrhosis of the liver, or to perform routine physical examinations, because Mrs. Bradley's insurance, at that time, was "exhausted." Dr. Armstrong provided some care to Mrs. Bradley without billing for procedures for which her clinic otherwise charged.
On July 6, 1998, Mrs. Bradley filed a motion to modify the dissolution decree in the Circuit Court of Boone County, alleging that a substantial and continuing change in circumstances had occurred which rendered the prior decree unreasonable. In support, she alleged that she was now disabled and unemployed, and had been unable to secure adequate employment, largely due to the severe medical problems she had developed since the entry of the original dissolution decree. She also stated that there had been a tremendous increase in the cost of living since the decree was entered almost 17 years earlier, including but not limited to a cost increase in property taxes and insurance on real property, and cost increases in basic necessities of living. She further stated that significant repairs had to be made to her home, she needed to buy a new car, and the amount of maintenance ordered 17 years earlier was no longer sufficient to meet these basic needs. Finally, she alleged that Mr. Bradley has experienced a substantial increase of income since the date of the original decree, and further noted that the minor children, for whom Mrs. Bradley had previously received $900 in child support payments monthly, were now emancipated adults and Mr. Bradley's support obligations toward them had ended.
On July 1, 1999, Mr. Bradley filed a counter-motion to modify, seeking a termination or reduction of his maintenance obligations. In support, he alleged that his income had been substantially reduced, that his expenses associated with the operation of his medical practice had increased substantially, and that his expenses had generally increased since the entry of the original dissolution decree. He noted that the $250,000 home in which Mrs. Bradley lived was unencumbered by debt, the mortgages having been satisfied by Mr. Bradley in 1994. He further alleged that Mrs. Bradley's unemployment was a result of her earlier voluntary lifestyle choices within her control — i.e., her abuse of alcohol — and therefore that she was not entitled to an increase in maintenance.
The court held a hearing on the motions on July 1, 1999, at which both Mr. Bradley and Mrs. Bradley presented oral and documentary evidence to the court. On July 20, 1999, nearly 18 years after entry of the original decree, the court denied both parties' motions to modify. The court found that Mrs. Bradley currently had a monthly income of $1,634 per month, with expenses of $2,639 monthly, an income gap of just over $1,000 per month. It nonetheless held that "the income changes in eighteen years do not yield a change so substantial and continuing as to make the 1981 decree unreasonable." The trial court found, in support of its ruling, that the fact that major expenses would occur at some point related to the upkeep and repair of Mrs. Bradley's home should have been foreseen at the time of the dissolution 18 years earlier — and, therefore, the fact that they were occurring now did not constitute a change in circumstances. The court specifically stated, with respect to home-related expenses, that "the maintenance of Respondent's residence, taxes thereon and other house-related expenses are not new, nor unexpected items which can justify modification."
The court further noted that "[c]learly at the time of the initial dissolution full payment of Respondent's [Wife's] mortgage debt, emancipation of the children and the completion of college for the children as well as the termination of child support were all foreseeable events and thus not matters to be taken into account as a change of circumstance." With respect to new expenses related to Mrs. Bradley's automobile, the court similarly stated that "car payments and new automobiles are anticipated or expected changes, foreseeable at the time the parties were divorced in 1981," and so also did not constitute a changed circumstance.
In addition, the court refused to consider the effects of inflation in determining whether the original maintenance award had become unreasonable, offering as justification for its refusal the reasoning that "all parties' income is similarly affected [by inflation]." Similarly, the court found that Mrs. Bradley's increased living expenses — such as higher utility payments — were not "unexpected or substantial," inasmuch as they were not "inconsistent with the general increase in the cost of living, which the Court, again, notes all affects [sic] the parties in the same manner." It is not clear whether the Court considered the $66 per month Mrs. Bradley now pays in taxes on the house, or the insurance payments due on the house.
Finally, the court concluded that, in its estimation, "the sole change the Respondent [Wife] can rely upon is her inability to work, matched by, or offset by, her increase in Social Security which amounts to a net loss of $277 per month" as compared to the income, other than maintenance, that Mrs. Bradley earned at the time of the 1981 decree." The court held that this was not a sufficiently changed circumstance to justify an increase in maintenance at this time. In light of all of its findings, the court ultimately denied both Mrs. Bradley's motion to modify, and Mr. Bradley's counter-motion to modify. Mrs. Bradley's appeal followed.
LEGAL ANALYSIS
Mrs. Bradley contends that the trial court erred in denying her request for increased maintenance because the evidence showed that her disability, the effects of 18 years of inflation, and the deterioration of property awarded her in the dissolution decree constitute substantial changes in circumstances that have rendered the $1,000 per month awarded in the original decree inadequate to provide for her reasonable needs. She asserts that it was error for the court to declare that these changes in circumstances were insufficient to justify an increase in maintenance simply because the possible occurrence of many of them was "foreseeable" at the time of the original maintenance order, and that it was improper for the court to discount the effects of her disability and ignore the effects of inflation on her ability to meet her reasonable needs.
A. Burden of Proof and Standard of Review.
A trial court has broad discretion in determining both the amount of maintenance, and the duration thereof. Whitworth v. Whitworth , 806 S.W.2d 145, 148 (Mo.App.W.D. 1991). For this reason, we will reverse an order granting or denying a modification of maintenance only when the order is not supported by substantial evidence, is against the weight of the evidence, or if the trial court erroneously declares or applies the law. Fulp v. Fulp , 808 S.W.2d 421, 423 (Mo.App.W.D. 1991); Murphy v. Carron , 536 S.W.2d 30, 32 (Mo.banc 1976).
Section 452.370 RSMo Cum. Supp. 1998, requires that a party requesting modification of maintenance satisfy a two-part test by showing both that a substantial change in circumstances has occurred since the time of the original decree, and that these changed circumstances have made the prior award of maintenance unreasonable. Milligan v. Helmstetter , 15 S.W.3d 15, 21-22 (Mo.App.W.D. 2000); Theilen v. Theilen , 911 S.W.2d 317, 318 (Mo.App.W.D. 1995); Kieffer v. Kieffer , 590 S.W.2d 915, 917 (Mo.banc 1979); Butler v. Butler , 698 S.W.2d 545, 548 (Mo.App.E.D. 1985). The burden of establishing changed circumstances that are sufficiently substantial and continuing as to render the original order unreasonable, thereby justifying a modification of maintenance, is upon the requesting party. See Thielen , 911 S.W.2d at 318.
In deciding whether the change in circumstances alleged by the movant has resulted in a change in the movant's reasonable needs, the court may — but is not required to — consider the factors set out in Section 452.335, which govern a court's award of maintenance in its original dissolution decree. See Brooks v. Brooks , 957 S.W.2d 783, 786 (Mo.App.W.D. 1997). The relevant factors which Section 452.335 directs the court to consider include assessments of "[t]he financial resources of the party seeking maintenance . . . the comparative earning capacity of each spouse . . . the age, and the physical and emotional condition of the spouse seeking maintenance . . . the ability of the spouse from whom maintenance is sought to meet his needs while meeting those of the spouse seeking maintenance . . . and . . . any other relevant factors." Sec. 452.335. The ultimate issue remains whether a substantial and continuing change in circumstances has occurred which has rendered the terms of the prior decree unreasonable.
The Trial Court Erred In Its Determination Whether Mrs. Bradley's Disability, Combined with the Effects of Inflation and the Parties' Changes in Income and Expenses, Constituted a Substantial Change In Circumstances.
The court appears to have accepted Mrs. Bradley's evidence that she is now disabled and unable to work for medical reasons, and had to draw social security, for it noted that her only income (other than maintenance) was Social Security of $634 per month, and held that "without considering why Respondent is drawing Social Security, such is the fact and to assign blame or fault would be unproductive." And, in fact, the record affirmatively shows that at the time her Motion to Modify was filed, Mrs. Bradley had been administratively found to be suffering from a "severe" disability, as defined under the Social Security Act, that precluded "even moderately strenuous activity," and that rendered her incapable of performing nearly any type of employment. It is also undisputed that, by contrast, at the time of the dissolution decree in 1981, Mrs. Bradley was physically able to work to help meet her reasonable needs. She worked during the marriage, and after the dissolution she worked for several years in a flower shop and in a factory, earning up to $2,400 per month, until the time that her disability prevented her from continuing work.
"In a modification proceeding, the concept of 'change' necessarily entails a departure from a known prior state or condition." Fulp , 808 S.W.2d at 423 . Accord, Lemmon v. Lemmon , 958 S.W.2d 601, 604 (Mo. App W.D. 1998). At the time of dissolution, Mrs. Bradley was able-bodied and able to work. At the time of her motion to modify, she was physically disabled and unable to work. The trial court's failure to find that the disability constituted a departure from prior known conditions which, if substantial, could support a finding that the prior award was unreasonable, was error. Physical disabilities which substantially impair one's ability to provide for oneself can constitute "substantial and continuing changed circumstances" for the purposes of Section 452.070. Butler , 698 S.W.2d at 549 (noting, among other relevant factors, that wife's complete inability to work due to breast cancer supports a finding of substantial and continuing changed circumstances); Waller v. Waller , 646 S.W.2d 135, 136 (Mo.App.E.D. 1983) (effects of polio, inflation and greater expenses justified increase in maintenance); Steib v. Steib , 672 S.W.2d 740 (Mo.App.E.D. 1984) (deterioration in health and husband's increase in income justified modification of maintenance); Fulp , 808 S.W.2d at 423 (acknowledging that, although the evidence before the Court did not support a finding of substantial and continuing changed circumstances in that case, health issues that affect current earning capacity can constitute "substantial and continuing changed circumstances that warrant modification").
Mr. Bradley does not directly deny that his former spouse is disabled, but instead suggests that we should lay moral blame on her and deny her motion to modify because she has only herself to blame for becoming disabled in the first place. In particular, Mr. Bradley argues, the court should consider his former wife's change in circumstances to be a result of her voluntary actions and on that basis should deny her motion to modify, because her problems first arose as a result of drinking caused by her depression over the divorce.
The case cited by Mr. Bradley and similar cases involving imputed income or denial of maintenance based on increases in expenses all involve situations in which a spouse voluntarily took a lesser-paying job, or retired early, and then sought a decrease in maintenance obligations based on reduced income. Leslie v. Leslie , 827 S.W.2d 180, 183 (Mo.banc 1992) (husband's voluntary early retirement without effort to obtain further employment, not grounds upon which he could predicate a claim of changed circumstances). See also Draper v. Draper , 982 S.W.2d 289, 292 (Mo.App.W.D. 1998) (reduction in ex-husband's yearly income did not justify a reduction or elimination of his maintenance obligation; reason for decrease in income was his decision to quit work and depend on long-term disability, and he presented no medical evidence to support his claim that his disability was permanent); Luker v. Luker , 861 S.W.2d 195, 199 (Mo.App.W.D. 1993) (in calculating child support obligation, father's refusal to take offered position at salary of $30,000 per year resulted in imputed income to him in that amount; proper to impute higher income to party when evidence indicates that party has capacity to earn higher income, and decision not to do so is voluntary). In such cases, the courts properly and consistently hold that the drop in income was voluntary and could not support a reduction in maintenance.
Mr. Bradley's cases do not apply to these facts. In those cases, the spouse in question could work but refused to do so. By contrast, here, whatever the original cause of her problems, the record unequivocally established that Mrs. Bradley is now physically disabled and that it is this physical disability that makes her unable to work. The Social Security determination of this substantial and permanent disability, without reference to the cause of that disability, controls here. She has a severe liver ailment which keeps her from earning enough money to pay her bills. The fact that Mrs. Bradley is now disabled and unable to work, whereas she was able to work and did work prior to the dissolution and during much of the time since, was clearly a change in circumstances which the court was required to consider, along with the other evidence, in determining whether the changes in circumstances were substantial and whether they rendered the terms of the original decree unreasonable.
In considering whether a substantial change in circumstances had occurred, the court was also required to consider changes in Mr. or Mrs. Bradley's financial situation, even if the fact that some of those changes in circumstances might occur could, theoretically at least, have been foreseeable at the time of the dissolution. In holding that it could not consider changes if the parties could have foreseen them, the court erred. The statutory vehicle for modification of maintenance awards, Section 452.370.1, exists to eliminate the need for trial courts, in making original awards of maintenance, to make delphic predictions of all possible contingencies in the far-flung future — no matter how implausible — that may conceivably have an effect on the "reasonable needs" of the person receiving maintenance. Indeed, to base a decision concerning the necessity, duration, or amount of a maintenance award upon speculative or unsupported predictions as to what the future may hold itself constitutes an abuse of discretion.
See Leslie , 827 S.W.2d at 184 ("In determining a former spouse's ability to support himself or herself in the future, the trial court should not speculate on evidence that might be adduced in a later modification proceeding."); Whitworth , 806 S.W.2d at 148. ("Neither an appellate court or a trial court may speculate on what the future might justify; rather such a determination should be made in a proceeding for modification of the award upon a showing of changed circumstances."); Burrus v. Burrus , 754 S.W.2d 882, 885-86 (Mo.App.W.D. 1988) ("In determining the spouse's ability to support him or herself in the future, the trial court may consider probable future prospects, but the evidence must justify the inference that the spouse will realize such expectations. . . . Maintenance shall not be prospectively decreased or terminated if there is no evidence nor reasonable expectation that the circumstances of the parties will be markedly different in the future." (internal citations omitted)).
Here, there is no evidence to support the lower court's conclusion that the judge that entered the original decree had any evidence before him of the possible future contingencies that Mrs. Bradley alleges are "substantial and continuing changed circumstances," nor that he considered such eventualities in calculating the original maintenance award of $1,000 per month. Moreover, in light of the prohibition against speculative maintenance awards, it would have been error had the dissolution court taken such possibilities into account in calculating the maintenance award, absent substantial evidence to justify the conclusion that such possibilities would occur in the near future. Lemmon , 958 S.W.2d 601 , relied on by Mr. Bradley, is not to the contrary. Lemmon does not hold that if it is foreseeable at the time of dissolution that an expense may occur at some future point, then that expense cannot be considered at any later modification proceeding. Lemmon states only the limited proposition that a court that awards income-producing property to a wife in a decree necessarily anticipates that she will receive income from that property. Therefore, the husband cannot later claim that the fact that the wife is receiving such income is a change of circumstances. It is not. The fact that such income would exist in the future was known at the time of the original decree. See Lemmon , 958 S.W.2d at 604 .
See cases cited in note 1. Although cases such as Leslie , Whitworth , and Burrus deal specifically with the issue of trial court error in prospectively limiting or terminating maintenance, the same rationale prohibiting speculative determinations of future "reasonable needs" would apply here.
Lemmon is applicable to the extent that taxes on the house and similar expenses were reasonably anticipated and taken into account at the time of the original decree. Here, however, the thrust of Mrs. Bradley's argument is that the court below should have considered major expenses which were not provided for in the original decree in determining whether a substantial change of circumstances had occurred which had rendered the terms of the original decree unreasonable. Clearly, such expenses can be considered in determining whether, due to her disability and other factors, she is unable to meet her reasonable needs.
Similarly, the Court erred in holding that the effect of 18 years of inflation could be ignored simply because everyone was subject to inflation in the same way. This holding, if given effect, would mean that the effects of inflation could never be considered in deciding whether a decree had become unreasonable. That is not the case. While all persons are subject to inflation, the effect of that inflation on their ability to meet their reasonable needs, or on their ability to continue paying a certain level of maintenance, may well not be the same. To persons with a disability and a resulting fixed income, like Mrs. Bradley, who are barely meeting their reasonable needs, inflation may be devastating. To a person with an increasing income, or with an income which is more than enough to meet his or her reasonable needs, inflation may be only unwelcome.
Of course, inflation in and of itself does not justify an increase in maintenance. But numerous cases have recognized, directly or by implication, that the effect of inflation on a person's ability to meet their reasonable needs is properly a factor to be considered by the courts in determining whether a substantial change of circumstances has occurred. Where a long period of time has elapsed since the initial decree, the effects of that inflation will support a modification if, considered alone or with other changes, they make the terms of the prior decree unreasonable. For example, in Waller , 646 S.W.2d at 136, the Court affirmed a finding of a substantial change in circumstances between the time of dissolution in 1975 and the motion to modify in 1981 based on evidence, similar to that in the instant case, that due to the effect of her polio disability and "spiraling inflation," wife was only able to work part-time and the amount of the original maintenance award was inadequate. Similarly, Moran v. Moran , 681 S.W.2d 510, 513 (Mo.App.E.D. 1984), in a case dealing with child support, held that twelve years of inflation could well support a finding of changed circumstances. See also Plattner v. Plattner , 567 S.W.2d 139, 142 (Mo. App E.D. 1978) (proper to consider effect of inflation).
By so holding, we do not mean to suggest that a court should find changed circumstances every time inflation occurs. As noted in Etling v. Etling , 747 S.W.2d 285 (Mo.App.E.D. 1988):
Where there has been a short period of time between the original decree and the time of filing the motion to modify the allegations must show an extra-ordinary change in circumstances. Expected and predictable increases are presumed to have been taken into account in the original award. Foster v. Foster, 673 S.W.2d 108 (Mo.App. 1984) [6]. Where a short period of time has elapsed aging and inflation are entitled to little consideration as they are, respectively, inevitable and predictable.
Id. at 287 (emphasis added) (assessing implications of inflation in child support case). Accord, Morgan v. Ackerman , 964 S.W.2d 865, 869-70 (Mo.App.E.D. 1998).
Moreover, even ignoring Mrs. Bradley's needs for repair of her home and a car, and even ignoring inflation, the court noted that there was a considerable change in Mrs. Bradley's income. At the time of the dissolution, Mrs. Bradley was earning $825 per month, plus $1,000 per month in maintenance, for a total of $1,825 per month. At the time the motion to modify came on for hearing, she was receiving $634 per month in social security, plus $1,000 per month in maintenance, for a total income of $1,634 per month. After taxes were considered, the court found that she was receiving $277 less per month in 1999, at the time of the hearing, than she had received in 1981, at the time of the dissolution, a more than 14% drop. If inflation is considered, this gap would be much greater.
The court further found that Mrs. Bradley had expenses in 1999 of $2,639 per month. This means that it found a gap of $1,005 per month between Mrs. Bradley's income and her expenses in 1999. When these facts are considered in light of the relevant factors set out in Section 452.335 — Mrs. Bradley's financial resources, her earning capacity, her age and physical condition — it is evident that she did not have sufficient financial resources to meet her reasonable needs, and that the effect of this change in her financial circumstances was substantial.
Of course, the fact that she needed more income to meet her needs would not necessarily entitle her to an increase in maintenance. The court must also consider whether Mr. Bradley had sufficient resources to meet his reasonable needs and, if so, whether he had the financial ability to pay her the additional maintenance she requested. The court found that Mr. Bradley was receiving $7,300 per month in income from his practice plus an unspecified amount in rental income. The evidence also showed that he paid his current spouse an additional amount of approximately $2,000 per month for her office assistance. While the court found, based on this evidence, that Mr. Bradley did have sufficient income to continue to pay his former spouse $1,000 per month in maintenance, the court did not reach the issue of whether he had sufficient income to pay her an increase in maintenance. Neither did the court make a finding as to the amount of his monthly expenses, nor as to the effect of inflation on his ability to meet his expenses with his current income. We must therefore remand this case so that the court can specifically address the following issues: whether Mr. Bradley can pay additional maintenance and still meet his reasonable needs; whether Mrs. Bradley is entitled to an increase in maintenance under the statute; and, if she is entitled to an increase in maintenance, how much of an increase is appropriate.
For all of these reasons, we remand this case to the circuit court with directions that the court consider the evidence of increased expenses offered by Mrs. Bradley, her disability and consequent loss of income, and the effects of inflation on both parties, and determine whether the changes in circumstances are so substantial as to have made the terms of the original decree unreasonable.