When the court orders permanent spousal support, it should also advise the supported party that he or she should make reasonable efforts to assist in providing for his or her support needs. This may only be dispensed with if the case involves a marriage of long duration (10 years or longer).
Failure on the part of the supported spouse to make reasonable efforts can constitute a change in circumstances that would warrant a modification in spousal support. The premise is that the supported spouse is already made aware of the obligation to become self-supporting and yet has done nothing about it.
The Gavron warning is quite important. One factor appellate courts consider in deciding whether a modification or termination of spousal support is proper is whether a Gavron warning was given.
Family Code § 4330(b)
The Gavron warning given by a California family court does not have a statutory definition, but California Family Code Section 4330(b) discusses the advisement:
(b) When making an order for spousal support, the court may advise the recipient of support that he or she should make reasonable efforts toassist in providing for his or her support needs, taking into account the particular circumstances considered by the court pursuant to Section 4320 , unless, in the case of a marriage of long duration as provided for in Section4336, the courtdecides this warning is inadvisable.California Family Code 4330(b)