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Under this doctrine, “[e]quitable relief will be denied if one comes to the court with unclean hands.” Noddin v. Noddin, 123 N.H. 73, 76 (1983).

Following a hearing, the court denied the respondent’s petition, stating: “[The respondent’s] incarcerated status does not warrant a reduction in his child support obligation.” The respondent moved for reconsideration, which the court denied “for the reasons discussed in Noddin v. Noddin, 123 N.H. 73, 76 (1983).” This appeal followed.

Prior to the enactment of RSA chapter 458-C, we held that a parent who was terminated from employment because of his own wrongdoing was not eligible for a reduction in support payments due to his reduced ability to pay.

Noddin v. Noddin, 123 N.H. 73, 76 (1983) (holding that a change in financial condition “due to fault or voluntary wastage or dissipation of one’s talents and assets,” is not grounds for modification), superseded on other grounds by statute as recognized by In the Matter of Sarvela and Sarvela, 154 N.H. 426, 435 (2006), and In the Matter of Rossino

In finding that the respondent was voluntarily underemployed and in imputing income to him based upon this finding, the trial court relied upon our decision in Noddin v. Noddin, 123 N.H. 73 (1983).

notice that the marital master found, in the related divorce case between the petitioner and Lucille Rossino, see In the Matter of Rossino & Rossino, 153 N.H. 282 (2006), that “the [Noddin] case applies since it was a result of Joseph A. Rossino’s own inappropriate conduct and voluntary actions that brought about his loss of employment with the Hudson Police Department.” See Noddin v. Noddin, 123 N.H. 73 (1983).

The respondent argues that the court erred in applying Noddin v. Noddin, 123 N.H. 73 (1983), to the facts of this case and in denying joint legal custody of his minor children.

The trial court adopted the petitioner’s requested rulings of law, including the standard that “[t]o obtain a modification of an alimony award, a change in circumstances of the parties must be shown which will *471 make the continuance of the original provisions ‘improper and unfair.’ Noddin v. Noddin, 123 N.H. 73, 76 (1983).” We agree with the respondent that Noddin does not fully articulate the standard for modification of an alimony award.

Assuming, without deciding, that the unclean hands doctrine could bar Cabletron from asserting the statute of limitations defense, see Noddin v. Noddin, 123 N.H. 73, 76, 455 A.2d 1051, 1053 (1983) (unclean hands doctrine may bar equitable relief), we hold that the doctrine does not apply under the circumstances of this case.

Based on these findings of breach, the court denied Miami Subs’ request for declaratory judgment, reasoning that Miami Subs had come to court with “unclean hands.” See Noddin v. Noddin, 123 N.H. 73, 76, 455 A.2d 1051, 1053 (1983).

In upholding the $5,000 wage assignment, the superior court relied on Noddin v. Noddin, 123 N.H. 73, 76, 455 A.2d 1051, 1053 (1983), where we held that a petition to modify an alimony or child support order will be denied if a “change in financial condition is due to fault or voluntary wastage or dissipation of one’s talents and assets.” Noddin, however, concerned the substantive grant or modification of a support

A modification should not be granted in the absence of evidence of a substantial change in circumstances of the parties arising since the grant of the initial award, “making the current support amount either improper or unfair.” Morrill v. Millard (Morrill), 132 N.H. 685, 689-90, 570 A.2d 387, 390 (1990); accord Noddin v. Noddin, 123 N.H. 73, 76, 455 A.2d 1051, 1053 (1983); Fortuna v. Fortuna, 103 N.H. 547, 548, 176 A.2d 708, 709 (1961).

The plaintiff argues that since the original order imposed no child support, and since the defendant continues to earn more than twice the income of the plaintiff, there has not been any change in circumstances as required under Noddin v. Noddin, 123 N.H. 73, 76, 455 A.2d 1051, 1053 (1983).

“The master has broad discretion in determining whether an alimony award should be modified or terminated.” Hannemann v. Newcomb, 125 N.H. 289, 292, 480 A.2d 132, 134 (1984) (citing Noddin v. Noddin, 123 N.H. 73, 75, 455 A.2d 1051, 1053 (1983); Collette v. Collette, 108 N.H. 469, 470, 238 A.2d 598, 598 (1968)).

ings’ to Defendant because her oldest son no longer lives with her certainly do not approach a proportionate percentage of the present $2,500/month amount.” “To obtain a modification of support or alimony obligations, the [party seeking a modification] must show such a change in circumstances of the parties as to make the continuance of the original order ‘improper and unfair.’” Noddin v. Noddin, 123 N.H. 73, 76, 455 A.2d 1051, 1053 (1983) (quoting Fortuna v. Fortuna, 103 N.H. 547, 548, 176 A.2d

*292 To obtain a modification of an alimony award, a change in circumstances of the parties must be shown as will make a continuance of the original provisions “improper and unfair.” Noddin v. Noddin, 123 N.H. 73, 76, 455 A.2d 1051, 1053 (1983) (quoting Fortuna v. Fortuna, 103 N.H. 547, 548, 176 A.2d 708, 709 (1961)).