What is the Voynick v. Voynick (2025) decision?

In Voynick, the NJ Appellate Division ruled that when a payor retires in good faith (presumed at full retirement age 67), the court must analyze the recipient's retirement savings. If the recipient has adequately saved and can maintain a reasonable standard of living, alimony may be reduced or terminated even if the payor could still afford payments.

What is Assembly Bill A1576 (2026)?

Introduced in January 2026, this bill would expand New Jersey's cohabitation law to include a mutually supportive intimate relationship even without shared residence, if the recipient receives economic benefits. The bill is pending and not yet law.

How does retirement affect alimony after Voynick?

If the payor retires in good faith (age 67+ presumed), the court examines whether the retirement is genuine, the recipient's need, and critically, whether the recipient has adequate retirement savings. If the recipient saved sufficiently, alimony may be terminated.

What is the new Case Information Statement (CIS) form?

Effective September 1, 2025, the new CIS form includes dedicated lines for cryptocurrency and digital assets, streaming subscriptions, and a separate schedule for seasonal expenses.

New Jersey Spousal Support Calculator | Alimony Estimates Under NJSA 2A:34-23

Use this free New Jersey spousal support calculator to estimate monthly alimony under NJSA 2A:34-23, updated with the 2025 Voynick v. Voynick retirement-savings ruling and the new 2025 Case Information Statement categories (digital assets, streaming subscriptions). Whether your divorce is filed in Bergen, Essex, Morris, Middlesex, Monmouth, Ocean, or Camden County, this tool weighs income, needs, marriage duration, and county cost-of-living factors. Under Voynick, when a payor retires in good faith, the court must examine whether the recipient has adequately saved for retirement — which may reduce or terminate alimony even if the payor could still afford payments. Always consult a licensed New Jersey family law attorney for advice tailored to your case.

Income Information

Payor's Gross Monthly Income :

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Recipient's Gross Monthly Income:

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Income Disparity Ratio:

Monthly Child Support Obligation:

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Marriage Details

Marriage Duration (years):

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Separation Date:

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Marriage less than 10 years?

Marriage 20+ years?

Is recipient custodial parent?

New Jersey-Specific Factors

County:

Alimony Type:

Marital fault involved?

Marital Fault Impact

Considered only if it affected economic circumstances of the parties.

See: Gnall v. Gnall, 222 N.J. 414 (2015)

Recipient cohabiting?

Cohabitation Rules

May be grounds for modification. Pending Bill A1576 (2026) may expand the definition to relationships without shared residence.

Professional License Held By:

Likelihood of Payor Retirement:

Needs and Resources

Recipient's Housing Costs ($/mo):

Health Insurance ($/mo):

Streaming/Subscriptions ($/mo) :

Other Essential Expenses ($/mo):

Payor's Essential Expenses ($/mo):

Digital Assets Value ($) :

Payor's Age:

Marital Standard of Living (1-10):

Earning Capacity & Retirement

Recipient's Education:

Years Recipient Out of Workforce:

Recipient sacrificed career for marriage?

Recipient has disability?

Has recipient adequately saved for retirement?

Duration Factors

Maintain marital standard of living?

Significant separate property?

Age Difference (years):

Recipient's Age:

Important Legal Disclaimer: This calculator provides estimates only. Updated to reflect Voynick v. Voynick (2025) regarding retirement savings. Pending Bill A1576 (2026) may change cohabitation rules. Consult a qualified attorney.

Estimated Alimony Results

Monthly Alimony Amount

Annual Alimony Amount

Estimated Duration

0 years

New Jersey-Specific Factors Applied

Note: This estimate includes the Voynick v. Voynick (2025) retirement savings factor. Actual awards depend on judicial discretion.

Modifying Alimony in New Jersey

Under NJSA 2A:34-23, alimony may be modified upon a showing of a substantial change in circumstances.

1. Legal Standards for Modification

Substantial Change Required: The change must be material and ongoing — temporary fluctuations are insufficient.

Automatic Termination on Remarriage: Alimony automatically terminates upon the recipient's remarriage.

Good-Faith Retirement Standard (Voynick): When a payor retires in good faith — presumed at full Social Security retirement age (67) — the court must analyze whether the recipient has adequately saved for retirement. The recipient's own retirement savings can justify reducing or terminating alimony, even if the payor could still afford payments (Voynick v. Voynick, 2025).

Cohabitation Currently Requires Shared Residence: Under current law, cohabitation-based modification generally requires shared residence — though pending Assembly Bill A1576 would expand this to a "mutually supportive intimate relationship" without cohabitation.

Marital Fault Rarely Relevant: Marital fault is considered only if it affected the economic circumstances of the parties (Gnall v. Gnall, 2015).

2. Common Grounds for Modification

Recipient's Remarriage: Automatic termination; payor should still file to formally close out the order.

Payor's Good-Faith Retirement: Presumed at age 67, subject to analysis of the recipient's own retirement savings (Voynick).

Significant Income Change: For either party.

Recipient's Cohabitation: Currently requires shared residence to qualify; watch for A1576's potential expansion.

Disability or Health Issues: Affecting either party's earning capacity.

3. Step-by-Step Modification Process

Step 1 – Gather Evidence: Retirement account statements, tax returns, pay stubs, proof of cohabitation or income change.

Step 2 – File a Motion: Submit a motion with the Family Court that entered the original order.

Step 3 – Complete a Case Information Statement (CIS): Use the current version, effective September 2025, which includes digital assets and streaming subscriptions.

Step 4 – Serve Notice: Formally serve the other party.

Step 5 – Attend the Hearing: The judge applies statutory factors, including the Voynick retirement-savings analysis where applicable.

Step 6 – Order on Modification: Effective from the filing date forward; not retroactive.

4. Critical Practical Considerations

Never stop paying without a court order: Doing so risks contempt and arrears accumulation.

No retroactive modification: Act promptly when circumstances change, since relief runs only from the filing date.

Document the recipient's retirement savings for Voynick claims: Payors relying on good-faith retirement should gather evidence of the recipient's own savings adequacy.

Watch A1576's progress: If enacted, this pending bill could significantly expand what counts as cohabitation for modification purposes.

NJSA 2A:34-23 | Voynick v. Voynick, N.J. Super. (App. Div. 2025) | Gnall v. Gnall, 222 N.J. 414 (2015) | Crews v. Crews, 261 N.J. Super. 439 (1993) | Assembly Bill A1576 (pending, introduced Jan. 2026)