Kaspari v. Kaspari, 971 N.W.2d 846

Jean and Thomas Kaspari married in 1983, separated in 2013, and Jean filed for divorce in 2019; they stipulated to property division and litigated spousal support.
The trial court originally awarded Jean $7,000/month spousal support indefinitely; this Court vacated the unlimited duration and remanded (Kaspari v. Kaspari, 2021 ND 63).
On remand the district court retained the $7,000/month amount but limited duration: support to continue until Thomas turns 65.
Jean earns about $57,000/year, testified she is "living paycheck to paycheck," reported expenditures ranging from ~$65,000 to ~$94,000 (Rule 8.2), and says she cannot afford a home or the parties’ prior standard of living.
Thomas is a physician earning over $400,000/year, keeps the marital home and mortgage, and the court found he has substantial discretionary spending and ability to pay.
The Supreme Court reversed and remanded, holding the district court failed to adequately explain why $7,000/month was necessary given the evidence of Jean’s need and the court’s rationale suggested impermissible income equalization.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the $7,000/month spousal award is supported by findings of need	Jean: award needed to preserve pre‑divorce standard of living and cover demonstrated expenses	Thomas: evidence does not show Jean needs $7,000/month; court ignored asset/debt split and overstated need	Reversed and remanded — amount not adequately explained or supported by findings of need
Whether the court impermissibly sought to equalize incomes	Jean: disparity in incomes and lifestyle justifies adjustment to maintain standard of living	Thomas: court improperly attempted to equalize incomes rather than address actual need; calculation appears arbitrary	Held that award "appears" to equalize incomes without rationale; insufficient explanation warrants remand
Whether the district court applied Ruff‑Fischer and considered needs/ability to pay	Jean: court considered Ruff‑Fischer factors and ability to pay; duration and amount justified	Thomas: court did not meaningfully tie Ruff‑Fischer findings to the $7,000 figure	Court found the factors were discussed but required a clearer explanation linking facts to the specific amount; remanded for additional findings or reconsideration

Kaspari v. Kaspari, 2021 ND 63, 958 N.W.2d 139 (remanded original indefinite spousal award)
Woodward v. Woodward, 2013 ND 58, 830 N.W.2d 82 (outlines Ruff‑Fischer factors and goal of adequate self‑support)
Willprecht v. Willprecht, 2021 ND 17, 954 N.W.2d 707 (court must consider needs and ability to pay; clear financial description helpful)
O'Keeffe v. O'Keeffe, 2020 ND 201, 948 N.W.2d 848 (substantial income disparity can support permanent spousal support when not adjustable by property division)
Fox v. Fox, 2001 ND 88, 626 N.W.2d 660 (affirmed award of support to maintain pre‑divorce standard of living for long marriage)
Schmuck v. Schmuck, 2016 ND 87, 882 N.W.2d 918 (standard of review for factual findings: not reversed unless clearly erroneous)