In the Matter of Herbert N. Fowler, Jr. and Cheryl K. Fowler

Summary

The court held that rehabilitative alimony remains appropriate in some circumstances but is not required in every case, and the trial court did not abuse its discretion by selecting that general approach. It nevertheless held that the award was inadequate in amount and duration because it did not reasonably account for the marital standard of living, the defendant's limited employment prospects and non-economic contributions, and the plaintiff's ample ability to pay. The judgment was reversed and remanded for a more equitable alimony award.