Boemio v. Boemio
Court of Appeals of Maryland
994 A.2d 911 (2010)
After a nearly 20-year marriage, Boemio (plaintiff), a Federal Reserve employee with two master's degrees, filed for divorce from Seixas (defendant), who lacked a college degree and worked as an administrative assistant. In setting alimony, the trial court considered all 12 statutory factors but also consulted the American Academy of Matrimonial Lawyers (AAML) guidelines to help translate those factors into a dollar figure, ultimately awarding Seixas $3,000 per month in permanent alimony. Boemio appealed, arguing the trial court improperly abandoned the statutory factors.
Whether a trial court may consider non-legislative guidelines, in addition to statutory factors, when crafting an alimony award.