## Facts

- Michael Lynn Martindale, M.D. (“Father”) and Margo Miller Martindale (“Mother”) married in 1983 and had four sons.
- Mother worked as a school teacher while Father completed medical school; after the first child was born, Mother became a full-time stay-at-home parent.
- The parties divorced in 1995 under a final decree incorporating a marital dissolution agreement (MDA).
- Under the decree and MDA, Mother received legal and physical custody of the children; Father was obligated to pay child support (including private school tuition) and $5,000 per month in rehabilitative alimony.
- The rehabilitative alimony was set to terminate at a specified future point tied to the youngest child’s early school years (effectively a fixed multi-year term).
- After the divorce, Father’s income increased substantially (from roughly $292,000 at divorce to more than $400,000 per year after 1997).
- Mother worked part-time at a medical clinic for about $15 per hour and obtained recertification to teach, but testified she could not maintain full-time employment because of the children’s needs.
- After the divorce, two of the sons developed significant learning disabilities, increasing the time Mother spent on their educational and related needs; the trial court found these learning problems were not contemplated when the MDA was executed.
- Before the alimony term expired, Mother filed a motion seeking to extend the rehabilitative alimony beyond its scheduled termination (and also sought other post-divorce relief not central to the appeal).
- Following an evidentiary hearing, the trial court ordered Father to continue paying $5,000 per month in rehabilitative alimony until the youngest child graduated from high school, but declined Mother’s request to convert the award to alimony in futuro.
- Father appealed, challenging the extension of rehabilitative alimony.

## Issues

1. Whether the trial court abused its discretion by extending a fixed-term rehabilitative alimony award beyond the original termination date based on post-divorce changes, including unanticipated learning disabilities of two children and Mother’s continued inability to become self-supporting as contemplated.

## Decision

- The Court of Appeals affirmed the trial court’s order extending rehabilitative alimony.
- The court held the record supported the trial court’s finding of a material, substantial change in circumstances that was not anticipated when the MDA was executed, including the children’s learning disabilities and increased demands on Mother as custodial parent.
- The court concluded the evidence supported the trial court’s determination that Mother had not been rehabilitated as originally contemplated and that an extension—rather than conversion to alimony in futuro—was within the trial court’s discretion.

## Legal Principles

- Rehabilitative alimony is intended to assist a spouse in achieving economic self-sufficiency when rehabilitation is feasible; Tennessee courts generally favor rehabilitative support over long-term support when appropriate.
- Periodic alimony provisions incorporated into a divorce decree may be modified upon a showing of a material and substantial change in circumstances that was not within the parties’ contemplation at the time of the decree.
- A trial court’s decision to modify or extend rehabilitative alimony is reviewed for abuse of discretion; appellate courts defer to supported factual findings and credibility determinations in domestic relations matters.
- In evaluating whether rehabilitation has occurred and whether modification is warranted, courts may consider the recipient spouse’s actual ability to work, efforts toward employment or retraining, the parties’ earning capacities, and caregiving obligations, including unanticipated special educational needs of children in the custodial parent’s care.
- Extending rehabilitative alimony for a time-limited period can be an appropriate remedy when the recipient spouse has made efforts toward rehabilitation but post-decree circumstances have delayed the anticipated transition to self-support.

## Conclusion

Martindale v. Martindale affirmed a trial court’s extension of $5,000 monthly rehabilitative alimony until the youngest child’s high school graduation because the evidence supported a material, unanticipated change in circumstances—most notably the development of learning disabilities in two children and the resulting increase in Mother’s caregiving and educational responsibilities—showing Mother had not achieved the rehabilitation contemplated when the parties agreed to a fixed term of support, and the trial court acted within its discretion in extending (but not converting) the award.


Martindale v. Martindale, 2005 WL 94366 (2005)