Cited by

(making this observation in the context of a child-support appeal); see Minn. Stat. § 645.44, subd.

See, (“Because the word ‘may’ is defined as ‘permissive,’ a district court has discretion to set the effective date of a maintenance modification.”).

see also Sinda, d at 181 (stating that an appellate court “review[s] the district court’s decisions regarding retroactivity for an abuse of discretion).

This court has stated that an award of permanent spousal maintenance “does not preclude an obligor from subsequently demonstrating that a recipient has, in fact, become self-sufficient.”

-21 (Minn. App. 2000) (holding that a district court has the discretion to set a n effective date for modification of spousal maintenance that post-dates the filing of the motion).

(making this observa tion in the context of a child- support appeal); see Minn. Stat. § 645.44, subd.

(addressing this aspect of Poehls).

Appellant “doubts that, in almost any instance, an award in the $300 range can be rendered unreasonable or unfair given that the dissolution decree awarded her ‘permanent’ maintenance.” But the fact that an award is deemed permanent “does not preclude an obligor from subsequently demonstrating that a recipient has, in fact, become self - sufficient.”

When determining whether a substantial change in income has occurred, making the maintenance obligation unreasonable and unfair, “the stipulation may be relevant if one party claims this change was not or could not have been anticipated.” Kemp v. Kemp

(setting forth this aspect of Poehls).

(stating that “maintenance depends on a showing of need”); (stating that “[a]bsent a demonstrated need [by a maintenance recipient, a maintenance obligor’s] continuing maintenance obligation should be terminated”).

Regarding the gym membership, to support his argument that the district court clearly erred by including a $50 gym membership in Sharon’s monthly expenses because the expense arose after the parties separated.

in which the obligee’s margin account loan payment was “temporary and more in the nature of an investment.” Finally, is also misplaced.