Kimberly A. Quinty v. Steven W. Johnson, 164 A.3d 135

Kimberly Quinty and Steven Johnson divorced in 2011 after an uncontested hearing; their negotiated settlement (incorporated into the judgment) required Johnson to pay general spousal support for five years, from March 1, 2011 through February 29, 2016.
On July 8, 2016 (about four months after the support term ended), Quinty moved to modify the judgment to reinstate and extend spousal support under 19-A M.R.S. § 951-A(4).
Johnson moved to dismiss under M.R. Civ. P. 12(b)(6), arguing the court lacked authority to reinstate spousal support after the award had fully terminated.
The District Court granted Johnson’s motion, relying on 19-A M.R.S. § 951-A(9) and controlling Maine precedent, concluding reinstatement after complete termination is barred.
Quinty appealed; the Supreme Judicial Court reviewed the dismissal de novo and affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a court may reinstate/modify spousal support after the award has completely terminated under its express terms	Quinty: the divorce judgment did not expressly preclude future modification, so § 951-A(4) allows modification	Johnson: once the award terminated on its stated date, § 951-A(9) and precedent bar reinstatement; Quinty’s motion was untimely	Court: Held reinstatement is precluded after complete termination; motion fails as a matter of law

Pettinelli v. Yost, 930 A.2d 1074 (Me. 2007) (reinstatement of spousal support barred after complete termination)
Raisen v. Raisen, 896 A.2d 268 (Me. 2006) (party must file a timely motion to extend fixed-term spousal support)
Spencer v. Spencer, 720 A.2d 1159 (Me. 1998) (court cannot reestablish spousal support after date of complete termination)