Elizabeth Gnall, Plaintiff-Respondent v. James Gnall, Defendant-Appellant

Summary

The Supreme Court of New Jersey reversed the Appellate Division's remand of a trial court's limited duration alimony award ($18,000 per month for eleven years) in a nearly fifteen-year marriage, finding that the appellate panel inadvertently created a bright-line rule - that a fifteen-year marriage is 'not short-term' and therefore precludes limited duration alimony - contrary to the legislative intent underlying N.J.S.A. 2A:34-23. The Court also concluded that the trial court itself had improperly weighed marital duration over the other statutory factors, effectively reserving permanent alimony for marriages of twenty-five years or more even though no such per se rule exists. All thirteen statutory factors must be considered and given due weight, with duration of marriage only one among them. The judgment of the Appellate Division was unanimously reversed and the case remanded to the trial court for new findings of fact and a new determination of the alimony award.