In Re the Marriage of Patricia F. Murphy and Michael J. Murphy Upon the Petition of Patricia F. Murphy, and Concerning Michael J. Murphy, 16-0831

Parties divorced by stipulated decree in 2005: Michael ordered to pay Patricia $2,750/month traditional spousal support until death or remarriage.
Michael remarried; currently practices at wife Kimberly’s law firm but has no ownership interest; draws $118,500 salary plus veteran disability/pension (~$1,676/month).
In 2015 Michael petitioned to modify/terminate support, citing declining health, memory issues, and intent to retire; no medical testimony was offered at trial.
Michael and Kimberly transferred ownership of assets (law firm interests, rental properties) so Michael has limited formal ownership, though they share income/expenses via joint accounts and a comfortable lifestyle.
Patricia continued managing the rental properties, reduced mortgage debt, and increased retirement savings, but still relies significantly on the spousal support for income and asserts health limits her ability to increase earnings.
District court denied Michael’s modification petition and awarded Patricia $16,362 in trial attorney fees; Michael appealed.

Issue	Michael's Argument	Patricia's Argument	Held
Whether spousal support should be modified/terminated due to Michael’s health and planned retirement	Michael: declining health and imminent retirement create a substantial change in circumstances justifying modification/termination	Patricia: Michael remains employed, earns more than at divorce, and asset transfers are meant to avoid support; she still needs support	Court: Denied modification — Michael failed to prove an unforeseeable substantial change; retirement not imminent; no medical evidence presented
Whether the district court abused its discretion in awarding Patricia attorney fees	Michael: fee award ($16,362) excessive; Patricia can pay her own fees; issue limited	Patricia: fees supported by affidavit; incurred costs including motions to compel and defending frivolous motions	Court: No abuse of discretion; fee award upheld

In re Marriage of Michael, 839 N.W.2d 630 (Iowa 2013) (standard for proving substantial change in spousal-support modification)
In re Marriage of Gust, 858 N.W.2d 402 (Iowa 2015) (prefer deferring retirement-based support changes until retirement is imminent or occurred)
In re Marriage of Skiles, 419 N.W.2d 586 (Iowa Ct. App. 1987) (medical problems of aging typically within contemplation at decree entry)
In re Marriage of Maher, 596 N.W.2d 561 (Iowa 1999) (trial court has considerable discretion to award attorney fees in family-law proceedings)