Woodward v. Woodward, 830 N.W.2d 82

Loren and Rita Woodward married in December 1991; they have no children.
Loren is a Navy veteran and BNSF Railroad employee earning about $78,000 annually.
Rita holds college degrees but currently earns about $27,000 annually.
Both parties had extramarital affairs near the end of the marriage; Loren admitted heavy drinking.
Rita previously had breast cancer, now in remission, and lacked health insurance after separation.
In 2011 the district court awarded Rita a net distribution and Loren $1,000 monthly as permanent spousal support, finding a relatively long marriage and lifestyle reductions for Rita.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether permanent spousal support was appropriate	Woodward argued rehabilitation was possible; permanent support not warranted	Woodward contends rehabilitation should suffice; permanent support not necessary	Affirmed; permanent spousal support appropriate under Ruff-Fischer guidelines
Whether cohabitation terminates spousal support	Not explicitly stated separately; focus on ongoing support	Cohabitation should not automatically terminate support	Not terminated by cohabitation; reaffirmed Cermak standard

Duff v. Kearns-Duff, 792 N.W.2d 916 (ND 2010) (guidelines and rehabilitation considered in spousal support)
Fischer v. Fischer, 139 N.W.2d 845 (ND 1966) (Ruff-Fischer factors applied to support awards)
Ruff v. Ruff, 52 N.W.2d 107 (ND 1952) (Ruff-Fischer framework for spousal support)
Becker v. Becker, 799 N.W.2d 53 (ND 2011) (support may be permanent to prevent unfair decline in living standards)
Moilan v. Moilan, 598 N.W.2d 81 (ND 1999) (goal is adequate self-support considering marriage standards and assets)
Cermak v. Cermak, 569 N.W.2d 280 (ND 1997) (cohabitation does not automatically terminate spousal support)