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In re Marriage of Mazzi11/6/2000
circumstances. The trial court's finding of such was error, but that error was harmless. The court properly found a severe economic hardship. Once it did so, it had wide discretion to modify the support order. Thus, although the court's finding of a substantial change of circumstances was error, even if that finding is removed, the court still had the authority to modify the order on the basis of its finding of severe economic hardship. This court will not reverse where the error was harmless.
6. Statutory modification provisions supercede common law doctrines of finality.
Because the statute expressly provides for modification of the order, common law doctrines of finality such as collateral estoppel are not applicable as they are superceded by the statutory provisions. Support orders are of ongoing duration and it is necessary to be able to modify them periodically as circumstances change or when they do not operate as intended. Such orders, and the underlying findings upon which they are based, are only final for the period of time provided in the statute.
7. Ms. Jallen's request for attorney fees is denied.
Ms. Jallen requests attorney fees on the basis that her financial resources are limited. This is not a legitimate basis for the award of legal fees on appeal and the request is denied.
The decision of the trial court is affirmed.
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