Alimony Modifications

Appellate Division Provides Much Needed Clarity on Alimony Modifications When a Payor Seeks an Early Retirement

The Appellate Division’s recently published (precedential) decision in Amzler v. Amzler provided much needed clarity on a question of first impression regarding early retirement and related applications to modify or terminate alimony obligations established prior to the 2014 amendments to our alimony statute. Specifically, the Appellate Division was presented with the question of whether N.J.S.A.…

New Appellate Division Decision on Cohabitation Addresses a Payor’s Prima Facie Burden

New Appellate Division Decision on Cohabitation Addresses a Payor’s Prima Facie Burden

When is a supported spouse’s proof of a mutually supportive intimate personal relationship with another person enough to overcome the first step in the process towards terminating alimony? In the recently issued unpublished (not precedential) decision of Goethals v. Goethals, the Appellate Division reversed a trial court’s decision finding that the payor failed to fulfill…