Change of Substantial Circumstances in Divorce Actions

A substantial change of circumstances is fact intensive:  “The term ‘substantial change of circumstances’ is well-known in family law.  It focuses on the facts.  It compares the facts then and now.  It requires that the facts on which the prior order was based differ from the present facts, and the difference is enough to justify the court’s considering whether to modify the order.”  Beaupre v. Airriess, 208 Wis.2d 238, 245-46 (Ct. App. 1997).