failed to recognize the distinction between permanent spousal support and rehabilitative alimony, Ron has failed to prove that Loita has gained a continuing legal obligation of support constituting a material and substantial change of circumstances. Ron argues that ”[t]he decisional law of Washington State ... makes use of quasi-marriage or de facto marriage in order to ... establish benefits and to settle claims to property_” However, Ron never asserts that David has a legal obligation to support Loita or cites any persuasive precedent. Loita correctly asserts that Washington law only creates “[r]ights to jointly acquired property [which] is not the same as a legal right to support, which is the issue in the instant case.” See Warden v. Warden, 36 Wash. App. 693, 676 P.2d 1037 (1984) (<HOLDING>). Ron also invites this court to reinstate
holding only that the statutory criteria for property division upon divorce apply to nonmarital relationships of long duration recognizing division of separate property to be contrary to statute and constitution holding res judicata applied to improper property division before holding parties were bound by their division agreement holding that reconsideration of the correctness of property division was barred on appeal from the judgment enforcing that division holding that an increase in the value of nonmarital property attributable to the efforts of one or both spouses during marriage is marital property