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November 2015 Archives

The Court Reinforces the Importance of the Alimony Factors

Gnall v. Gnall, 222 N.J. 414 (2015) stems from a fifteen year marriage that ended in divorce. The trial judge found, among other considerations, that permanent alimony was not appropriate due to the relatively young age of the parties, their educational levels, and the duration of the marriage. The judge determined that the marriage "certainly was not short-term, but neither [was it] a twenty-five to thirty-year marriage." The trial Court awarded the Wife limited duration alimony for a period of eleven years. The Wife appealed, arguing she was entitled to permanent alimony. The Appellate Division reversed and remanded the case for an award of permanent alimony, reasoning that a fifteen-year marriage is "not short-term," therefore precluding "consideration of an award of limited duration alimony."