Clapp v. Clapp
Vermont Supreme court
653 A.2d 72 (1994)
After a 25-year marriage during which Elizabeth Clapp (plaintiff) initially stayed home with the couple's children before earning a master's degree and becoming a school guidance counselor, and Michael Clapp (defendant) built a legal career, the couple divorced with a substantial income disparity ($45,237 versus $137,600 before taxes). The court ordered Michael to pay maintenance calculated through after-tax income equalization dating back to their 1987 separation, and Michael appealed, arguing Elizabeth could meet her own reasonable needs from her own income and that her nonmonetary homemaking contributions were not a valid basis for maintenance.
Whether, in determining maintenance, a spouse's reasonable needs are based on the spouse's relative needs rather than absolute need.