In re the Marriage of Mills

Summary

The court held that a spouse’s permanent disability acquired during a marriage may support an award of traditional spousal support even when the marriage is shorter than the usual durational threshold. Because the disability permanently eliminated Erinn’s earning capacity and Jason could pay, the court approved $400 per month in traditional support, but rejected an automatic increase when child support ends. The court vacated the court of appeals’ decision, modified and affirmed the district court’s order, and remanded for recalculation of child support.