Calculate Alimony Under Maryland Family Law § 11-106
Recommended Alimony Type:
Primary Factors:
Guideline Amount:
Recommended Duration:
Likely Range:
Key Factors:
Reaffirmed that rehabilitative alimony is the standard award. Indefinite alimony requires a finding of "unconscionable disparity" that persists even after the recipient becomes self-supporting.
Held that a payor's voluntary early retirement (age 62) without health issues does not automatically justify alimony modification; the court must weigh the parties' reasonable expectations and financial needs.
Indefinite alimony may be awarded when the parties' standards of living will be "unconscionably disparate" even after the recipient becomes self-supporting.
Cohabitation may be grounds for modification or termination of alimony if it results in a change in the recipient's financial needs.
Significant reforms took effect October 1, 2025:
Pendente Lite: During divorce proceedings.
Rehabilitative: For education/training to become self-supporting.
Indefinite: For long-term needs; requires a finding of unconscionable disparity.
Maryland uses 12 statutory factors (MD Family Law § 11-106), including marriage duration, standard of living, age, health, earning capacity, contributions as homemaker, and financial needs. There is no strict formula; judges have broad discretion.
Under 5 years: Typically no alimony unless exceptional circumstances.
5-20 years: Alimony for 20-50% of marriage duration.
20+ years: May receive indefinite alimony in appropriate cases.
Yes. Automatic termination upon remarriage. Modification requires a material change in circumstances (e.g., retirement, disability, significant income change). Under Chen v. Kuo (2025), early retirement is not automatic grounds for modification.
Payor may petition to modify at reasonable retirement age (typically 65+). Courts examine health, financial resources, and the parties' expectations. Early retirement (before 65) may not be considered reasonable unless health-related.
Urban counties (Montgomery, Howard) typically award higher alimony due to higher cost of living. Rural counties generally award lower amounts. Judges consider local housing costs and wage levels.