## Facts

- Elizabeth Gnall and James Gnall met in college, married eight years later, and were married for nearly fifteen years before Elizabeth filed for divorce in 2008.
- Elizabeth, a college-educated computer professional, became a full-time homemaker and primary caretaker of the couple’s three children.
- James, a certified public accountant, became a high-level finance executive and was the family’s sole wage earner, with annual compensation reaching about $1.8 million by 2008.
- The parties maintained an upscale marital lifestyle.
- The dispute centered on the amount and type of alimony—limited duration versus permanent.

## Issues

1. Whether an appellate court may treat a marriage of approximately fifteen years as categorically “not short-term,” effectively barring limited duration alimony and requiring permanent alimony.
2. Whether alimony type and duration must be determined through an individualized application of the statutory factors in N.J.S.A. 2A:34-23(b), rather than by a duration-based bright-line rule.
3. Whether the Appellate Division improperly displaced the Family Part’s fact-sensitive discretion in its review of the alimony award.

## Decision

- The Supreme Court of New Jersey reversed the Appellate Division.
- The Court held that the Appellate Division erred by creating and applying a bright-line rule that elevated marital duration to a controlling threshold.
- The matter was remanded to the Family Part for reconsideration of alimony under a proper application of N.J.S.A. 2A:34-23(b), without categorical rules tied solely to the length of the marriage.
- The Court did not reinstate the original alimony award; it required a fresh determination under the correct legal standard.

## Legal Principles

- Alimony awards must be based on the full set of statutory factors in N.J.S.A. 2A:34-23(b); marital duration is important but not dispositive.
- Courts may not use categorical, duration-based rules that automatically require or preclude permanent alimony or limited duration alimony.
- Family Part determinations on economic issues in divorce are entitled to appellate deference absent abuse of discretion or legal error; appellate review should not substitute a generalized rule for a trial court’s factor-based findings.
- On remand after legal error, the proper remedy may be reconsideration under the correct standard rather than automatic reinstatement of the prior order.

## Conclusion

The court rejected a duration-only approach to alimony classification and required that the type, amount, and length of alimony be decided through an individualized, multi-factor analysis under N.J.S.A. 2A:34-23(b), with appropriate deference to Family Part fact-finding.


Gnall v. Gnall, 222 N.J. 414, 119 A.3d 891 (N.J. 2015)