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You’ve Come a Long Way, Alimony
As Family Dynamics Have Changed, Tennessee’s Alimony Law Has Evolved to Keep Pace
In March, the Tennessee Bar Association published the 10th Edition of the Alimony Bench Book. This useful tool is edited by members of both the bench and bar who strive to keep us informed and up to date on the current law and trends in alimony awards (and denials) across the state and provide useful information on enforcement, collection, taxation and bankruptcy of alimony. This article is written in celebration of the 10th Edition of the Alimony Bench Book and the efforts made by the Tennessee Legislature to enact an alimony statute that has kept pace with the changes in our society.
History of Alimony
As society has changed, the laws of alimony have evolved throughout history to keep pace with the values and way of life of present-day society. Alimony originated in English ecclesiastical courts. These courts would grant alimony to wives when granting a divorce a mensa et thoro.
That is a divorce from bed and board, where the marriage was not dissolved completely and the wife was in need of support because she could not own property and was not free to remarry.
Tennessee followed suit with the legislature originally only authorizing alimony if the parties obtained a divorce from bed and board and not in cases of absolute divorce. In 1835 and 1842, the Tennessee General Assembly enacted statutes that allowed the courts to provide for a “suitable allowance” from the property of the husband. However, the Tennessee Supreme Court made clear in Chenault v. Chenault, that such support was limited by the standard of living available to the husband. Eventually, in 1858, the Tennessee Legislature enacted statutes that the Tennessee Supreme Court interpreted to allow the courts to award alimony, even in cases of absolute divorce, in the form of monetary payments, periodic or lump sum, or through a property division. The legislature affirmed this holding in 1932, by amending the statute to expressly provide for the continuing jurisdiction of the trial court over an alimony award. Over the next 70 years, the Tennessee legislature would slowly work to tweak the factors to be applied to alimony in Tennessee and provide for additional types of alimony to be considered by the courts.
In 1983, the Tennessee legislature made significant revisions to the statutory framework of alimony to clarify the role of alimony in Tennessee divorces and to provide courts with a list of factors to consider in determining the nature, amount, length and manner of alimony. Through its amended statute, the Tennessee legislature stated that whenever possible, alimony was to be “rehabilitative and temporary.” This language was even further clarified in 1984, when the legislature amended the statute to state that “[i]t is the intent of the general assembly that a spouse who is economically disadvantaged relative to the other spouse be rehabilitated whenever possible by the granting of an order for the payment of rehabilitative, temporary support and maintenance.” In 1993, the Tennessee legislature amended the alimony statute to explicitly create the third type of alimony, rehabilitative alimony, separate from alimony in solido or periodic alimony.
Keeping pace with a changing society, where more women were becoming educated and working outside the home, the Tennessee legislature made further amendments in 2003, creating a fourth type of alimony, transitional alimony. This fourth type was to be awarded when rehabilitation was not necessary, but a spouse needed assistance adjusting to the economic consequences of divorce. However, the legislature codified its public policy in support of the family unit enacting language that “[i]t is the public policy of this state to encourage and support marriage, and to encourage family arrangements that provide for the rearing of healthy and productive children who will become healthy and productive citizens of our state.” The amended statute explained that “[s]pouses have traditionally strengthened the family unit through private arrangements whereby one spouse focuses on nurturing the personal side of the marriage, including care and nurturing of the children, while the other spouse focuses primarily on building the economic strength of the family unit. This arrangement often results in economic detriment to the spouse who subordinated such spouse’s own personal career for the benefit of the marriage.” In support of this public policy, the Tennessee legislature amended the alimony statute to provide the benchmark for rehabilitation:
where one spouse suffers economic detriment for the benefit of the marriage … the economically disadvantaged spouse’s standard of living after the divorce should be reasonably comparable to the standard of living enjoyed during the marriage or to the post-divorce standard of living expected to be available to the other spouse, considering the relevant statutory factors and the equities between the parties.
With this standard in mind, many seem to be wondering about the state of alimony in Tennessee, when marriages often consist of two parties that are both educated and have careers outside the home or perhaps when one spouse, with some education and training, could return to or begin a career outside the home.
Gonsewki v. Gonsewski
Recently in Gonsewski v. Gonsewski, the Tennessee Supreme Court granted review to determine “whether alimony in futuro should be awarded to a spouse who has a college degree, good health, a stable work history in a relatively high paying job, and a lack of demonstrated need for such long-term alimony.” In doing so, the Tennessee Supreme Court provided us with a in-depth review of the legal analysis to be applied in cases involving a claim for alimony. After a thorough discussion on the state of the law regarding alimony in Tennessee, the Tennessee Supreme Court reversed the Court of Appeals and affirmed the trial court’s denial of alimony in futuro.
The Husband and Wife in Gonsewski were married for 21 years before they divorced and had two adult daughters. The parties were each 21 years old at the time of marriage and 42 years old at the time of divorce. At the time of marriage, Wife had graduated from college and was employed. Husband, however, was completing his last year of college and thereafter took a job as an accountant. Both spouses worked full-time throughout the marriage.
At the time of divorce trial, Wife was employed as an information technologist by the State of Tennessee, where she had been working for 16 years. Wife earned a base salary of $72,000 per year with a longevity bonus of $1,500 each year. Husband worked as the comptroller for a restaurant equipment manufacturer, where he had been employed since 2004. Husband earned a base salary of $99,000 per year plus bonuses. Husband’s bonuses in 2008, the year before the trial, amounted to $33,115. However, Husband testified that the bonuses were based upon the performance of the company and were expected to decline in the coming years. Wife failed to present any evidence to the contrary regarding Husband’s expected bonuses.
As the Supreme Court explicitly noted, there was little evidence presented at trial as to the parties’ standard of living during the marriage or that expected to be enjoyed by the parties after the divorce. The evidence did show that both parties had college degrees, had worked throughout the marriage, neither had a physical or mental condition that would affect alimony, and both “parties received comparable shares of marital property,” with Wife receiving slightly more. It was also shown that the parties’ two daughters resided with Husband and he took out loans to pay their college expenses.
The trial court denied Wife alimony, “explaining that she had a stable job with the state, earned a good income, and that her share of the equity in the marital home was sufficient to find another residence.” Also, the trial court denied both parties’ request for attorney fees upon finding that the fees they incurred where due to each spouse’s unnecessary filings and litigiousness.
On appeal, the Middle Section Court of Appeals reversed the trial court, awarding Wife $1,250 per month in alimony in futuro and her attorney’s fees incurred both at trial and on appeal. The Court of Appeals found that Husband’s income had been consistently much greater than Wife’s, with Husband earning almost $60,000 more than Wife the year preceding the divorce. Finding that Wife could not be rehabilitated, the Court of Appeals held that Wife was the “economically disadvantaged spouse,” and that her earning capacity would not permit her to maintain a standard of living after the divorce that is reasonably comparable to that enjoyed during the marriage or by Husband after the divorce. Further, the Court of Appeals found that Wife was entitled to recover at least some of her attorney fees, at trial and on appeal, as Wife did not have sufficient income or adequate assets from which to pay her attorney fees.
In reversing the Court of Appeals, the Tennessee Supreme Court reminded us that alimony in futuro “is intended to provide support on a long-term basis if ‘the court finds that there is relative economic disadvantage and that rehabilitation is not feasible.’” The court explained that to be rehabilitated means “that ‘the disadvantaged spouse is [able] to achieve, with reasonable effort, an earning capacity that will permit the spouse’s standard of living after the divorce to be comparable to the standard of living enjoyed during the marriage, or to the post-divorce standard of living expected to be available to the other spouse.” However, as noted in Gonsewski and the cases since, it is not uncommon for the standard of living of both parties after the divorce to decline.
In reviewing the facts of Gonsewki, the Tennessee Supreme Court found that, based upon the evidence presented, the wife was not in need of alimony in futuro. The court found that both spouses received comparable shares of the marital estate, with Wife receiving slightly more, and both had made equal contributions to the marriage. Also, both parties had relatively comparable salaries, with Wife earning $72,000 a year plus bonuses, and Husband earning $99,000 per year plus bonuses, which the evidence showed were expected to decline. Further, the court found that the parties’ two adult children lived with Husband when home from college and that Husband was assisting both with their education expenses, by obtaining loans for their college expense. Finally, the court noted that Husband had paid $1,206 per month in alimony pendente lite to Wife for 16 months, during the pendency of the divorce. Based upon these factors, giving the appropriate deference to the trial court, the Tennessee Supreme Court held that Wife was not in need of permanent alimony.
The Tennessee Supreme Court did not alter the law on alimony in Tennessee in Gonsewski v. Gonsewski. It merely restated and clarified how courts should be analyzing and awarding alimony, in light of today’s society. That is, a society that consists of many marriages where both spouses have higher education, both spouses have worked outside the home throughout the marriage, a spouse could return to the workforce with a reasonable amount of education and training to provide support for herself or himself at the marital standard of living, or where often both spouses are either both performing the role of bread-winner and homemaker or perhaps are even reversing roles. The Tennessee Supreme Court re-enforced the four types of alimony that the legislature has provided and the trial court’s ability to utilize those types, even in combination, to provide for today’s changing society and the support of the family.
Tennessee has four types of alimony: alimony in futuro, alimony in solido, rehabilitative alimony, and transitional alimony. In determining nature, amount and duration of alimony payments, trial courts are to consider the following factors:
- The relative earning capacity, obligations, needs, and financial resources of each party, including income from pension, profit sharing or retirement plans and other sources;
- The relative education and training of each party, the ability and opportunity of each party to secure such education and training, and the necessity of a party to secure further education and training to improve such party’s earning capacity to a reasonable level;
- The duration of the marriage;
- The age and mental condition of each party;
- The physical condition of each party; including, but not limited to, physical disability or incapacity due to a chronic debilitating disease;
- The extent to which it would be undesirable for a party to seek employment outside the home because such party will be custodian of a minor child of the marriage;
- The separate assets of each party, both real and personal, tangible and intangible;
- The provisions made with regard to the marital property as defined in § 36-4-121;
- The standard of living of the parties established during the marriage;
- The extent to which each party has made such tangible and intangible contributions to the marriage as monetary and homemaker contributions, and tangible and intangible contributions by a party to the education, training or increased earning power of the other party;
- The relative fault of the parties in cases where the court, in its discretion, deems it appropriate to do so; and,
- Such other factors, including the tax consequences to each party, as are necessary to consider the equities between the parties.
The two most important facts are the disadvantaged spouse’s need and the obligor’s ability to pay.
Alimony in futuro, or periodic alimony, provides for spousal support on a long term or permanent basis. This type of alimony provides support to be paid at regular intervals until death or remarriage of the recipient, when the disadvantaged spouse cannot be rehabilitated. It should only be awarded when the court finds that rehabilitation is not feasible. This means that the “disadvantaged spouse is unable to achieve, with reasonable effort, an earning capacity that will permit the spouse’s standard of living after the divorce to be reasonably comparable to the standard of living enjoyed during the marriage, or to the post-divorce standard of living expected to be available to the other spouse.” It is not, however, a guarantee that the recipient spouse will forever be able to enjoy a lifestyle equal to that of the obligor spouse. Alimony in futuro is modifiable. Because it is modifiable and terminates only upon death or remarriage, it also lacks sum certainty. It may also be awarded in combination with rehabilitative alimony, transitional alimony or alimony in solido.
The second type of alimony, alimony in solido, is sum certain as it provides for a lump sum. Like alimony in futuro, alimony in solido, is also a form of long-term support. However, the total amount to be paid is ascertainable on the date of divorce. While it is a sum certain award, it may be payable over a definite period of time. Alimony in solido may be awarded to adjust the division of marital property or compensate a spouse for the decrease in value of her separate property due to the other spouse’s actions. The trial court may consider a party’s future income when making an award of alimony in solido. The trial court may also award attorney’s fees as alimony in solido. “Such awards are appropriate only when the spouse seeking them lacks sufficient funds to pay his or her own legal expenses or the spouse would be required to deplete his or her resources in order to pay them.” However, such awards should be denied if a spouse has engaged in inappropriate litigation tactics. As shown in Gonsewki, a party who chooses to be litigious during preliminary matters, may ultimately win, but still be denied alimony in solido for attorney fees. Alimony in solido may also be awarded in combination with any other form of alimony.
The third type of alimony, the statutorily preferred type, is rehabilitative alimony. While there is a statutory preference for rehabilitative alimony, it does not displace long-term alimony in futuro when necessary. Rehabilitative alimony is intended to assist an economically disadvantaged spouse in acquiring additional education or training to achieve the standard of living of the other spouse. Rehabilitative alimony may be modified, including being terminated or extended. However, it must be modified during the period in which it is awarded. Rehabilitative alimony may be awarded in combination with alimony in solido or alimony in futuro.
The fourth type of alimony, transitional alimony, is utilized when rehabilitation is not necessary and is a form of short-term support. The trial court may award transitional alimony to a spouse who needs assistance adjusting to the economic consequences of a divorce. “[T]ransitional alimony is designed to aid a spouse who already possesses the capacity for self-sufficiency but needs financial assistance in adjusting to the economic consequences of establishing and maintaining a household without the benefit of the other spouse’s income.” It is not modifiable unless the parties agree otherwise.
Those practicing in this area must understand each type of alimony, the proof required to succeed on a request for alimony, and the deference to be given to the trial court.
Gonsewski v. Gonsewki provided us with a helpful reminder of the four types of alimony that exist in Tennessee. Each form has its unique rules and purposes. It is imperative that practitioners in this area fully understand each type of spousal support, including the purpose behind it, its definition, and any applicable limitations. We should be cognizant of the tools the legislature has provided to us for developing awards of alimony that are appropriate and fair given each unique set of circumstances. This includes the ability to combine the types of alimony awarded to meet a particular situation. For example, if a spouse can only be partially rehabilitated, a trial court can award both rehabilitative alimony and alimony in futuro. Moreover, if rehabilitation is not feasible, the trial court may award a combination of alimony in futuro and transitional alimony to assist the disadvantaged spouse. The trial court may award alimony in solido in combination with any of the other types of alimony. Consequently, Tennessee courts have a distinct tool to create an award of spousal support, using a combination of the four types, to meet the unique facts and circumstances that each different family may present. However, those practicing in this area, must be aware at the beginning of each case of the type or types of alimony a party may be requesting. As the Tennessee Supreme Court hinted in Gonsewski, “it may be prudent for parties to set forth in their pleadings the specific types of alimony sought.”
Awards of alimony are not guaranteed. One seeking an award of alimony must come forward with the appropriate proof. The alimony statute provides 12 factors that the court must consider in determining the type and amount of alimony, if any to award. However, the two most important factors are the need of the disadvantaged spouse and the obligor’s ability to pay. An award of alimony is an extremely fact-intensive decision. As indicated in Gonsewski, it is important to come forward with sufficient proof of one’s need or the other’s ability to pay. This likely means that more proof will be necessary than a simple income and expense statement. This is particularly true because need and ability to pay are determined in light of the standard of living enjoyed during the marriage, or the standard enjoyed by the other spouse after the divorce.
It is important for the party seeking alimony to prove the standard of living during the marriage or the post-divorce standard of living of the other spouse; i.e., whether lavish, frugal or somewhere in between. For example, to demonstrate a standard of living one might include such information as where the parties traveled, how they traveled, how often they traveled, and where they stayed when traveling; or how often the parties went out to eat and where they normally went; where the parties shopped; the parties’ hobbies; the parties’ club memberships; whether the parties have household staff to assist them; and any other information that may show how the parties lived during the marriage. Any award of alimony should reflect that standard of living enjoyed by the parties during the marriage or that of the other spouse after marriage. For example, if the parties regularly ate peanut butter sandwiches while on vacation, any alimony award should take this into consideration and not be based upon the standard of living one spouse would like to have enjoyed. Other proof may include: economic consequences of maintaining a home without the benefit of the other spouse. Any award of alimony, will be based upon such proof as presented to the trial court.
The party seeking alimony should also consider the nature of alimony sought and the remaining factors and present evidence in support of their claims. For example, if seeking rehabilitative alimony, the party should present evidence of what he or she could do or not do to alter an earning capacity. This includes any necessary training, the cost of such training and its impact on earning capacity.
Finally, it should be understood that an award of alimony is an extremely fact-intensive decision and involves the careful balancing of many factors. In Gonsewski, the Tennessee Supreme Court reviewed the standard of review to be applied in alimony cases, reiterating the deference to be provided to the trial court. As the Supreme Court explained, trial courts have broad discretion to determine whether spousal support is needed and, if so, the nature, amount, and duration of the award. The trial court’s decision on whether to award alimony and the type, amount and duration of any alimony award is reviewed for an abuse of discretion. An abuse of discretion occurs when the trial court (1) applies an incorrect legal standard, (2) reaches an illogical result, (3) resolves the case on a clearly erroneous assessment of the evidence or (4) relies on reasoning that causes an injustice. The appellate court is not permitted to substitute its judgment for that of the trial court.
The legislature has provided us with a useful tool in the form of the alimony statute. Today’s families are as varied in their forms and function as there are number of families. While there are still many traditional families, with the bread-winning husband and the home-maker wife, there are numerous other variations. Often, in today’s marriages, both spouses have some form of higher education. Perhaps husband and wife have reversed the traditional roles, and husband is performing the home-maker role and wife the role of bread winner. Perhaps while both have higher education, one spouse has temporarily left the work force to care for children. Maybe both spouses have continued to work, while combining their efforts to both perform the more traditional home-maker and child rearing roles. While no one form or function is the “right” one, the legislature has provided us with an alimony statute to encourage the family arrangement that works best for each family, while providing for and protecting both spouses, no matter their familial role, in the event of a divorce.
- Gonsewski v. Gonsewski, 350 S.W.3d 99, 106 (Tenn. 2011)(citing 2 Homer H. Clark Jr., The Law of Domestic Relations in the United States §17.1 (2d ed. 1987)).
- Id. see also Homer at 221.
- Krog, Gregory, “Tennessee Alimony Reform,” 14 Mem. St. U. L. Rev. 219, 219-20 (citing 1799 Tenn. Pub. Acts. § 9).
- 37 Tenn. 248, 252 (1856).
- Swan v. Harrison, 42 Tenn 534 (1865); see also Krog, at 222.
- Tenn. Code Ann. § 8446 (1932); Krog, at 228.
- Tenn. Code Ann. § 36-5-101 (1984).
- Tenn. Code Ann. § 36-5-101(1993).
- Tenn. Code Ann. §36-5-101 (2003).
- Tenn. Code Ann. § 36-5-101(d)(1)(D(2003).
- Tenn. Code Ann. § 36-5-101(d)(1)(A)(2003).
- Tenn. Code Ann. §36-5-101(d)(1)(B) (2003).
- 350 S.W.3d 99 (Tenn. 2011).
- Id. at 103.
- Id. at 104.
- Id. at 111.
- Id. at 104.
- Id. (citing Gonsewski v. Gonsewski, No. M2009-00894-COA-R3-CV, 2010 Tenn. App. LEXIS 117 (Tenn. Ct. App. Feb 17, 2010)).
- Gonsewski v. Gonsewski, No. M2009-00894-COA-R3-CV, 2010 Tenn. App. LEXIS 117, *15 (Tenn. Ct. App. Feb 17, 2010).
- Id. at *20.
- Gonsewski, 350 S.W.3d at 111.
- Id. (citing Tenn. Code Ann. § 36-5-121(f)(1)).
- Id. at 113.
- Id. at 111-12.
- Id. at 111.
- Tenn. Code Ann. § 36-5-121(i).
- Gonsewski, 350 S.W.3d 99, 110 (citing Riggs v. Riggs, 250 S.W.3d at 457; Bratton v. Bratton, 136 S.W.3d 595, 605 (Tenn. 2004); Robertson v. Robertson, 76 S.W.3d 337, 342 (Tenn. 20002); Burlew v. Burlew, 40 S.W.3d 465, 470 (Tenn. 2001)).
- Tenn. Code Ann. § 36-5-121(f)(1); Gonsewski, 350 S.W 3d at 107.
- Tenn. Code Ann. § 36-5-121(f)(1).
- Tenn. Code Ann. § 36-5-121(f)(1).
- Gonsewski, 350 S.W.3d at 108.
- Tenn. Code Ann. § 36-5-121(h).
- Tenn. Code Ann. 36-5-121.
- Burlew v. Burlew, 40 S.W.3d 465, 471 (Tenn. 2001)
- Broadbent v. Broadbent, 211 S.W.3d 216 (Tenn. 2006).
- Tippens-Florea v. Florea, No. M2011-00408-COA-R3-CV, 2012 Tenn. App. LEXIS 361 *26 (Tenn. Ct. App. May 31, 2012).
- Gonsewski, 350 S.W.3d 114 (citations omitted).
- Id. (denying alimony in solido for attorney fees incurred based upon each party’s litigiousness including harassing behavior, unplugging phones, making too many calls in rapid succession to the other’s cell phone, placing a plant on Wife’s car, preventing teenager from having access to her clothes, litigating over ski trip and car insurance, and more).
- Tenn. Code Ann. § 36-5-121(e).
- Tenn. Code Ann. §36-5-121(e)(2).
- Gonsewski, 350 S.W.3d at 109. See also Owens v. Owens, 241 S.W.3d 478, 493 (Tenn. Ct. App. 2007).
- Gonsewski, 350 S.W.3d at 109.
- Anderson v. Anderson, No. M2005-02029-COA-R3-CV, 2007 WL 957186 (Tenn. Ct. App. Mar. 29, 2007).
- Watson v. Watson, 309 S.W.3d 483 (Tenn. Ct. App. 2009).
- Gonsewski, 350 S.W.3d at FN11.
- Tenn. Code Ann. §36-5-121(i).
- Gonsewski,350 S.W.3d at 110 (citations omitted).
- Id. at 111.
- Walker v. Walker, No. M2006-00071-COA-R3-CV, 2007 Tenn. App. LEXIS 148 (Tenn. Ct. App. March 22, 2007).
- Gonsewski, at 111.
- Id. at 105.
- Id.; See also, Bratton v. Bratton, 136 S.W.3d 595, 605 (Tenn. 2004); Burlew v. Burlew, 40 S.W.3d 465, 470 (Tenn. 2001); Crabtree v. Crabtree, 16 S.W.3d 356, 360 (Tenn. 2000).
- Id. (citing Wright ex rel. Wright v. Wright, 337 S.W.3d 166, 176 (Tenn. 2011); Henderson v. SAIA Inc., 318 S.W.3d 328, 335 (Tenn. 2010)).
AMY J. AMUNDSEN is a partner with Rice Amundsen & Caperton PLLC in Memphis. She is a Rule 31 listed family law mediator, is completing her term as president of the Leo Bearman Sr. American Inn of Court. She is chair of the Tennessee Bar Association’s Alimony Bench Book Committee and former chair of the TBA and Memphis Bar Association’s Family Law Sections. She received her law degree from the University of Memphis Cecil C. Humphreys School of Law.
MARY L. WAGNER is an associate with Rice, Amundsen & Caperton PLLC in Memphis. She is an associate member of the Leo Bearman Sr., American Inns of Court and has interned for Tennessee Court of Appeals Judge Steven Stafford and Shelby County Circuit Court Judge Robert L. Childers. She received her law degree, magna cum laude, in 2009 from the Cecil C. Humphreys School of Law at the University of Memphis.