Kaspari v. Kaspari, 958 N.W.2d 139

Jean and Thomas Kaspari married in 1983; Jean is a registered nurse and Thomas is a physician. Jean moved out in 2013 and filed for divorce in 2019.
The parties stipulated to marital property division; the district court adopted the stipulation after an August 2020 trial.
The district court ordered Thomas to pay Jean $7,000 per month in "permanent spousal support until her death or remarriage."
Applicable statutory authority: N.D.C.C. § 14-05-24.1(1), amended in 2015 to permit spousal support "for a limited period of time."
Thomas appealed, arguing the award was legally impermissible because it was unlimited in duration; the Supreme Court vacated the spousal-support portion of the judgment and remanded for reconsideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an award of spousal support "until death or remarriage" complies with N.D.C.C. § 14-05-24.1(1)’s requirement of a "limited period of time"	Jean relied on prior language in cases referring to "indefinite permanent support," arguing indefinite awards have been recognized	Thomas argued the 2015 amendment changed "any period of time" to "a limited period of time," requiring a fixed duration and prohibiting unlimited awards	Court held "a limited period of time" requires a set duration; the award until death or remarriage is indefinite, so the spousal-support order was vacated and remanded for reconsideration

Hagerott v. Morton Cty. Bd. of Comm’rs, 778 N.W.2d 813 (N.D. 2010) (statutory interpretation is fully reviewable de novo)
Gooss v. Gooss, 951 N.W.2d 247 (N.D. 2020) (rules for reading statutory language and resorting to extrinsic aids)
In re Estate of Elken, 735 N.W.2d 842 (N.D. 2007) (primary purpose of statutory interpretation is to determine legislative intent)
Meier v. North Dakota Dep’t of Human Servs., 818 N.W.2d 774 (N.D. 2012) (presumption that Legislature acts with purpose)
O’Keeffe v. O’Keeffe, 948 N.W.2d 848 (N.D. 2020) (discussed "indefinite permanent support" in context of rehabilitative vs non‑rehabilitative support, not duration under § 14‑05‑24.1)
Krueger v. Krueger, 748 N.W.2d 671 (N.D. 2008) (prior use of phrase suggesting non‑rehabilitative support can be indefinite)