Young v. Young and Marital Lifestyle

In the Young v. Young case, the Massachusetts Supreme Judicial Court considered how to frame the need for alimony.  Is it the need to maintain the standard of living the recipient spouse had at the time of the separation leading to the divorce?  Or is it the amount required to enable the standard of living the recipient spouse would have had in the future if the couple had not divorced?  In this case, the SJC held that the answer is the need for support to maintain a life consistent with the marital lifestyle, not a future lifestyle. 

In this high net worth case, the Wife was a stay-at-home mom, by the parties’ agreement, who the judge found had no ability to secure employment that would allow her to maintain a lifestyle post-divorce similar to her marital lifestyle without alimony.  The SJC discussed how, given the Husband’s substantial ability to pay, the analysis rested on the Wife’s need: “that is, the amount necessary to allow her to maintain the lifestyle she enjoyed prior to the termination of the marriage.” Since the Husband’s income increased over the marriage, and the parties’ lifestyle grew more expensive along with it, the Wife’s need should be considered as the lifestyle she had grown accustomed to before the marriage ended.  The SJC concluded that, “Even if the parties enjoyed an upwardly mobile lifestyle for the duration of their marriage, nothing in the language of the statute or our case law suggests that the recipient spouse is entitled, by way of alimony, to enjoy a lifestyle beyond what he or she experienced during the marriage.”

It is worth also noting that the Probate and Family Court judge had ordered the Husband to pay alimony in the amount of 33% of his gross annual income.  The SJC discussed the special circumstances in which a proportionate or contingency award might be appropriate, and held that those types of circumstances were not present here.  The SJC remanded the matter so the Probate and Family Court judge could reevaluate alimony as a consistent amount, rather than a percentage.