Gnall v. Gnall (073321), 119 A.3d 891

Elizabeth and James Gnall married in 1993, had three children, and divorced after nearly 15 years of marriage; Elizabeth was a long‑term stay‑at‑home parent from 1999 onward and James was the sole wage earner earning over $1M/year at times.
Trial court conducted an 18‑day trial, made specific findings under the statutory alimony factors (N.J.S.A. 2A:34‑23(b)), and awarded limited duration alimony of $18,000/month for 11 years (to 2021), finding permanent alimony unwarranted given the parties’ ages, education, and marriage length.
Appellate Division reversed and remanded for consideration of permanent alimony, declaring that a 15‑year marriage is “not short‑term” and therefore precluding limited duration alimony.
James appealed to the New Jersey Supreme Court, arguing the Appellate Division created an improper bright‑line rule based on marriage length and that the trial court’s findings deserved deference.
The Supreme Court reversed the Appellate Division, holding that duration is only one of many statutory factors, trial courts must consider permanent alimony first and make specific findings if denying it, and neither the trial court nor appellate court may apply a rigid bright‑line rule based solely on marriage length.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused discretion by awarding limited duration alimony rather than permanent alimony	Gnall: 15‑year marriage and Elizabeth’s diminished employability warrant consideration of permanent alimony first	Gnall: trial court properly weighed statutory factors and reasonably concluded permanent alimony not warranted	Reversed appellate court; remanded for new findings — trial courts must consider permanent alimony first and weigh all statutory factors; no automatic rule based on 15 years
Whether the Appellate Division improperly created a bright‑line rule that marriages of ~15 years require permanent alimony	Gnall: Appellate Division did not create a general rule; its statement was case‑specific and urged fuller statutory analysis	James: Appellate Division created an impermissible bright‑line rule elevating duration above other factors	Held: Appellate Division effectively created a bright‑line rule and erred; duration is only one factor and cannot alone dictate permanent alimony

Cesare v. Cesare, 154 N.J. 394 (trial‑court findings binding on appeal when supported by credible evidence)
Mani v. Mani, 183 N.J. 70 (alimony should not operate as punishment/windfall)
Mahoney v. Mahoney, 91 N.J. 488 (alimony relates to post‑marital standard of living; reimbursement concept)
Lepis v. Lepis, 83 N.J. 139 (rehabilitative alimony purpose and standards)
Cox v. Cox, 335 N.J. Super. 465 (limited duration alimony appropriate for shorter‑term marriages; duration distinguishes limited vs. permanent when factors are otherwise equal)
Crews v. Crews, 164 N.J. 11 (purpose of permanent alimony to preserve marital standard of living)