Gordan v. Rozenwald
The statutory standard for the modification of Limited Duration Alimony (NJSA 2A: 34-2c) has been to apply retroactively.
Prior to the adoption of the Limited Duration Alimony statute term or limited duration alimony could not be ordered by the Court, but was often agreed upon by the parties and then incorporated into the judgement.
The issue presented was when a Court is now called upon to review agreement which predates the statute, should the statutory standards be applied?
Judge Jane Grall, an experienced Family Court Judge before her elevation to the Appellate Court, ruled that regardless of the date of the agreement or the judgment incorporating it, a motion to modify it must be governed under the standards of the statute.