A Court has wide discretion in determining alimony payments. Of course, the two most important factors in making an alimony determination are (1) the income disparity between the parties and (2) the manner and lifestyle of the spouses during the marriage. The Court’s standard of review in these matters is as follows:
“Our standard of review regarding . . . [an] award of alimony is whether the trial court abused its discretion.” Moran, 839 A.2d at 1097. An award of alimony should reflect the “reasonable needs in accordance with the lifestyle and standard of living established by the parties during the marriage, as well as the payor’s ability to pay.'” Id. (quoting Twila v. Twilla, 445 Pa. Super. 86, 664 A.2d 1020, 1022 (Pa.Super. 1995)). Further, “alimony following a divorce is a secondary remedy and is available only where economic justice and the reasonable needs of the parties cannot be achieved by way of an equitable distribution award and development of an appropriate employable skill.” Id. (quoting Twilla, 664 A.2d at 1022) (emphasis in original). “The purpose of alimony is not to reward one party and to punish the other, but rather to ensure that the reasonable needs of the person who is unable to support himself or herself through appropriate employment, are met.” Id. at 1096 (quoting Twilla, 664 A.2d at 1022).
Wife claims that: (1) the award of $500.00 per month for a period of 24 months was insufficient; (2) the award included an improper penalty if she were to challenge the alimony award; (3) the Master “downplayed the conspicuous disparity between Husband’s income of $5,692.87 and Wife’s income [of] $1,765.91 stating that the difference is not large,” Wife’s Br. at 36; (4) Husband’s expert’s testimony should not have been admitted; and (5) because Wife is in school and it will take 4 years of part-time study for her to complete her bachelor’s in education, the alimony award should be for a period of 4 years rather than 24 months.
The trial court upheld the Master’s findings indicating that the Master considered the relevant factors and considered the Pennsylvania Support Guidelines in determining the duration and amount of alimony. The Court found that any deviation from the guidelines was supported by the evidence as submitted to the Court. This included the relative education, income disparity and other relevant factors. Notably the Court indicated that the Master acknowledged that Husband had a higher income than Wife and that the difference in earnings would likely continue into the near future. The Master determined that the factor regarding the parties’ incomes weighed in Wife’s favor. We find the trial court did not abuse its discretion in upholding the Master’s Recommendations concerning the award of alimony. Granville v. Granville, 2017 Pa. Super. Unsub. LEXIS 3138, *16-22, 2017 WL 3574186 (Pa. Super. Ct. Aug. 18, 2017)
The takeaway here is that Master’s decisions are difficult to challenge unless they are very obviously inequitable and unexplainable. Certainly, the abovementioned amounts are not inequitable enough to be challenged.