Spousal Support Award Was Modifiable Despite Subsequent Show Cause Consent Order

In the case of Brown v. Brown, the Virginia Court of Appeals, in a published opinion, ruled that a husband could modify his spousal support obligation despite the fact that wife had to show cause him after the divorce for nonpayment of an arrearage and the resulting consent decree contained language which paralleled that contained in the parties final decree of divorce concerning husband’s obligation to pay support.