Any party who decides to modify spousal support must consider all factors as set forth in Family Code §4320. Irmo West (2007) 152 Cal.App.4th 240, 247.) A change of circumstances justifying modification of support must be shown in either a reduction or an increase in the supporting spouse’s ability to pay or in the supported spouse’s needs. (Irmo Dietz (2009) 176 Cal.App.4th 387, 396.)
California courts agree that changed circumstances can be found in factors such as an annuity payment derived from a party’s property, because it reduces the supported party’s need for support. The existence, and not the source of sums of money or services available, is considered the relevant factor in such a case.