A spousal support obligation may be reduced upon a showing of a material change in circumstances. A reduction in the payor’s income, if proved, would constitute a material change in circumstances warranting such a reduction. However, if the Court determines that the payor is voluntarily underemployed, the Court will impute income to the payor. In a recent Virginia Court of Appeals case, the Court ruled that the payor was voluntarily underemployed, when he made no effort to secure additional employment beyond making one telephone call.
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