In Re Marriage of Liddle v. Liddle
Denial of maintenance in 21 year marriage affirmed. Trial court not required to consider all statutory factors.
In Re Marriage of Lindsey v. Lindsey
Court articulated reasons for departing from Bahr rule where it referred to relative health of the parties and projected future ability to create income.
In Re Marriage of Harris v. Harris
Wife not entitled to more maintenance solely because husband can afford to pay more – husband should not be punished for making more money.
In Re Marriage of Kennedy v. Kennedy
Court abused its discretion by failing to apply statutory factors and not giving full play to the objectives of maintenance. The court considered ability to pay, but did not discharge its duty by simply equalizing the post-divorce income. The court should have considered the feasibility of the party seeking maintenance to become self-supporting and the length of time necessary to achieve this goal.
In Re Marriage of Parrett v. Parrett
“Good fortune and highly elevated income” are factors the court can consider in determining maintenance. LaRocque fairness objective applies to a short marriage.
In Re Marriage of Enders v. Enders
(1) LaRocque mandates an approach, not a result. (2) Reduction of income available for maintenance to pay business expenses was reasonable. (3) Although it is not recommended, offset of child support against maintenance is affirmed.
In Re Marriage of Fowler v. Fowler
Multiple issues. See full summary.
In Re Marriage of Gerth v. Gerth
Maintenance is not required in every long term marriage where there is disparate income. Here, wife did not increase her husband’s earning capacity or sacrifice her own.
In Re Marriage of Bisone v. Bisone
Trial court did not abuse its discretion when it found that wife’s future income would be reasonably comparable to her standard of living during the marriage. Trial court need not guarantee the same standard.
In Re Marriage of Forester v. Forester
Trial court did not fully consider statutory factors when it did not mention wife’s ability to become self-supporting in the future. Failure to consider wife’s earning capacity was a misuse of discretion.