Legal Question in Family Law in Florida

In a short term marriage is there a presumption against awarding permanent alimony?

The duration of marriage being less than 10-years makes this a short term marriage. See Iribar v. Iribar, 510 So.2d 1023, 1024 (Fla. 3d DCA

1987) (10 year marriage is short term). In short term marriages where

the partners are still young and able, the presumption is for

rehabilitative alimony rather than permanent. Reeves v. Reeves, 821

So.2d 333, 334 (Fla. 5th DCA 2002) (holding that in case of a short term

marriage, a presumption against awarding permanent alimony arises,

but such presumption is rebuttable); Green v. Green, 672 So.2d 49, 51

(Fla. 4th DCA 1996) (�This was a short-term marriage, and generally

permanent alimony is inappropriate unless a genuine inequity is created

by the dissolution.�); Geddes v. Geddes, 530 So.2d 1011 (Fla. 4th DCA

1988) (no error in awarding only rehabilitative alimony after 9 year

marriage to 45-year old spouse who was self sufficient before marriage

and there was no reason why she could not become so again);

Contogeorgos v. Contogeorgos, 482 So.2d 590 (Fla. 4th DCA 1986)

(holding that for 9-year marriage where wife was 29-years old and able to

be self-sufficient rehabilitative alimony should have been awarded;

reversing permanent periodic alimony as inappropriate); Campbell v.

Campbell, 432 So.2d 666 (Fla. 5th DCA 1983), petition for review

dismissed, 453 So.2d 1364 (Fla. 1984) (after a 10-year marriage a 34-

year-old wife should have received only rehabilitative alimony, not

permanent).