When a trial court enters an order for alimony, in conjunction with the entry of a divorce decree, under Pennsylvania’s Divorce Code, the alimony order is subject to being modified, suspended, terminated, or reinstated upon changed circumstances of either party of a substantial and continuing nature. Such an order, modifying, terminating or suspending an alimony order under the Divorce Code, “shall apply only to payments accruing subsequent to the petition for the requested relief.”

In the recent case of Crocker-Fasulo v. Fasulo, 292 A.3d 591 (Pa. Super. 2023), the court addressed a petition to modification or termination of alimony filed by the husband. The pertinent facts of the Fasulo case are as follows: at the time when the parties married in 1982, the husband was in medical school. After the parties married, the husband continued his medical training and the wife continued to work until the birth of the parties’ first child in 1987. The parties separated in 1998 and the wife filed for divorce approximately 11 years thereafter in 2009. Following a hearing, in 2010, the court entered a final divorce decree in 2012, which ordered permanent alimony to the wife in the amount $8,500 per month. After the entry of the divorce decree, the husband began to experience symptoms of Parkinson’s Disease.

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