Chin v. Merriot

Summary

The Massachusetts Supreme Judicial Court held that the retirement and cohabitation provisions of the Alimony Reform Act of 2011 apply prospectively and do not provide a basis for terminating an alimony order entered before the Act's effective date. The court concluded that such a preexisting alimony judgment remains governed by the prior material-change-in-circumstances standard, except for the Act's durational-limit provisions. The court affirmed dismissal of Chester Chin's complaint for modification.

Holdings

1. The Alimony Reform Act applies prospectively to the alimony obligation at issue because the divorce judgment was entered before March 1, 2012.
2. General Laws c. 208, § 49(d) and (f), do not independently authorize termination or modification of an alimony judgment entered before March 1, 2012, absent a material change in circumstances under the law applicable when the judgment entered.
3. A preexisting alimony judgment remains subject to the material-change-in-circumstances standard applicable before enactment of the Alimony Reform Act, and Chin failed to satisfy that standard.

Questions Presented

1. Whether the Alimony Reform Act of 2011 applies to a merged alimony provision in a divorce judgment entered before the Act's effective date.
2. Whether the Act's retirement and cohabitation provisions provide a basis for terminating a preexisting alimony obligation without proof of a material change in circumstances.
3. Whether the Probate and Family Court abused its discretion in dismissing Chin's modification complaint.

Disposition

affirmed