In re Mittelstaedt

Ruling: 
Decrease in income when debtor quit job and spouse retired was not a "special circumstance" that would prevent dismissal for abuse.
Issue: 
Did debtor's spouse's decision to retire and debtor's decision to leave job and move to Florida constitute "special circumstances" that would rebut the presumption of abuse and prevent dismissal of debtor's bankruptcy case?
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Consumer case opionion summary, case decided on February 28,2014, LexisNexis #0314-127