* * * * * * 10. That the purpose of spousal maintenance is to care for the wife's needs after divorce, not to provide her with a lifetime profit-sharing plan, Kaiser v. Kaiser, 290 Minn. 173, 186 N.W.2d 678 (1971); that, although the maintenance award was permanent, Petitioner had an obligation to retrain or rehabilitate herself so as to increase her earning power; that there has not been a substantial change in the financial circumstances of the parties as contemplated by M.S. Chapter 518.64, Subd. 2; that the failure of the Petitioner to increase her earning potential with an award of permanent alimony at age 45 should not become the husband's responsibility and basis for an increase in maintenance, See Crampton v. Crampton, (Minn.App. 1984); and that Petitioner's motion for an increase in spousal maintenance should be and is hereby denied. (emphasis supplied)
But in Videen, it was clear that wife's motion was for a "modification" of spousal maintenance and, unlike here, did not require the court to interpret any terms in the judgment related to spousal maintenance. Husband also relies on Crampton v. Crampton, 356 N.W.2d 768 (Minn.App. 1984). In Crampton, the judgment provided that "at the conclusion of * * * 96 months, the question of alimony shall be `reserved.'"
When support or maintenance are initially reserved and later addressed by the court, they are addressed under the standard for setting, rather than modifying, those obligations. Bennyhoff v. Bennyhoff, 406 N.W.2d 92, 94 (Minn.App. 1987) (support); Crampton v. Crampton, 356 N.W.2d 768, 771 (Minn.App. 1984) (maintenance). Initial awards of custody and visitation are governed by the best-interests standard.
" This court has affirmed that one party's failure to rehabilitate "should not become [the other party's] responsibility." Crampton v. Crampton, 356 N.W.2d 768, 770 (Minn.App. 1984). Therefore, the trial court did not abuse its discretion when it denied appellant's motion to modify its original award of temporary maintenance to a permanent award.
In light of these findings, supported by the record, the trial court was within its wide discretion to order appellant's maintenance obligation to continue despite his large debts. See Ganyo v. Engen, 446 N.W.2d 683, 687 (Minn.App. 1989) (addressing similar situation and holding that "given all the circumstances of the case," the trial court's decision to award maintenance in an amount that left the obligor with a $200 deficit per month was within its discretion); see also Crampton v. Crampton, 356 N.W.2d 768, 770 (Minn.App. 1984) (where maintenance arguments are "properly addressed to the trial court," an appellate court "cannot substitute * * * [its] judgment on * * * [their] merits"). 2. Appellant's Expenses
Appellant argues that respondent's willful failure to try to rehabilitate is different from an unsuccessful attempt to rehabilitate and should preclude her, as a matter of law, from receiving any further maintenance. Among the several cases appellant cites is Crampton v. Crampton, 356 N.W.2d 768, 770 (Minn.App. 1984), in which this court affirmed the district court's ruling that the wife's failure to rehabilitate "should not become [the husband's] responsibility." In this case, however, the district court awarded respondent permanent and increased maintenance, despite respondent's failure to rehabilitate.
The trial court did not err in considering appellant's earning capacity rather than his actual income in determining his maintenance obligation. Relying on Crampton v. Crampton, 356 N.W.2d 768 (Minn. Ct. App. 1984), appellant also argues that because he has paid maintenance for a period of time (5 years) equal to half of the time the parties were married (10 years), there is no "just reason" for him to continue paying maintenance. Such an argument stems from a misreading of Crampton, which does not state that maintenance should be paid for a period equal to one half the duration of the parties' marriage.
Minn.Stat. ยง 518.64, subd. 1 (1984). See also Crampton v. Crampton, 356 N.W.2d 768, 770 (Minn.Ct.App. 1984). II.
When maintenance is established in the decree but is left open for review at a later time, the issue is governed by standards for a modification. See Crampton v. Crampton, 356 N.W.2d 768, 771 (Minn.Ct.App. 1984). The trial court concluded that the monthly payments of $200 described in the decree were to pay for the automobile and were in reality part of the property division.