By Michael Stangarone and Laura Singer ( March 14, 2023, 8:29 AM EDT) -- In Assayag-Shneer v. Shneer, [2023] O.J. No. 98, the Ontario Court of Appeal sent a clear message to spousal support payors: orders containing a punitive penalty provision will not be varied absent a material change in circumstance. The mere fact that an order has a penalty provision within it is not sufficient to qualify for a variation. This is particularly true when the order is made on consent. The applicable rule to change a spousal support order remains the same: there must be a material change in circumstances....