In Indiana, what many folks think of as “alimony” is legally referred to as “spousal maintenance.” Unlike some states where alimony can be awarded based on fairness or need alone, Indiana only allows spousal maintenance in a minimal set of circumstances. The case of Matzat v. Matzat illustrates how carefully courts evaluate these requests and what evidence is required to support them. 

Background of the case

In the Matzat case, a couple who were married for a long time ended up divorcing. After the split, the wife asked the court for spousal maintenance, saying she couldn’t hold a job or support herself because of ongoing health issues. The court agreed with her and granted her request, basing its decision mostly on her own account of her medical condition. But the former husband pushed back and filed an appeal. He argued that the court got it wrong. According to the former husband, there was no actual medical proof that she was unable to work and support herself, and that her testimony alone should have been sufficient for the court to rule in her favor. 

Indiana has limited grounds for spousal maintenance

Indiana does not award ongoing alimony simply because one spouse earns more than the other. Instead, Ind. Code § 31-15-7-2 provides three narrow situations where maintenance can be ordered. These include:

• Physical or mental incapacity – Any disability that impacts a spouse’s ability to support themselves. 
• Caring for a disabled child – If the spouse has to be the primary caregiver to a disabled child, they can be awarded alimony. 
• Rehabilitative maintenance – You can get up to three years of support to obtain an education or training for a career. 

In the Matzat case, the wife argued that she was disabled and could not work.

Court of Appeal’s decision

In this case, the Court of Appeals decided to overturn the wife’s maintenance award, pointing out that there was no solid medical evidence to back up the wife’s claim that she couldn’t work. While she did testify about her condition, she did not provide any medical records or expert opinions to support her statements. Under Indiana law, that simply is not enough. 

The court acknowledged that trial judges do have some flexibility when making these decisions, but stressed that their rulings still need to be grounded in objective, verifiable evidence. To qualify for incapacity-based maintenance, a spouse must meet a few specific requirements. These include:

• There must be a formal diagnosis of a physical or mental condition,
• That condition must seriously impact their ability to work, and
• There needs to be dependable proof—usually from a doctor, medical files, or an official disability assessment.

Since those pieces of evidence weren’t presented in this case, the court concluded that the maintenance award wasn’t justified and reversed the decision. 

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