Question juridique clé
Whether the spousal maintenance reduction should apply retroactively before July 2012 because of the wife’s IV pension
Solution extraite
No further retroactive reduction was justified; the prior agreement had already taken the wife’s possible replacement income into account.
Motifs extraits
The parties knew of the wife’s health problems and the foreseeable possibility of replacement income when concluding the 2011 agreement, and they made no reservation allowing later retroactive adjustment.