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Mahoney v. Mahoney

Supreme Court of New Jersey
453 A.2d 527 (N.J. 1982)


Facts

Melvin Mahoney (plaintiff) filed a petition for divorce from June Mahoney (defendant) after approximately eight years of marriage. When the Mahoneys married, Melvin had an engineering degree, and June had a Bachelor of Science degree. During the marriage, Melvin enrolled in a program to obtain a Master of Business Administration (MBA) degree. During the 18 months that Melvin was a student, he contributed no income to the household, while June contributed $24,000. At trial, June sought reimbursement for the amount of support that she had provided to Melvin during the time he sought his MBA degree. The trial court granted June’s request and held that Melvin’s education and MBA degree were property subject to equitable distribution. However, instead of placing a value on the degree itself, the trial court ordered Melvin to reimburse $5,000 to June. June appealed. The appellate court reversed and held that neither a professional license nor an educational degree could be considered property for the purposes of equitable distribution. June appealed. The Supreme Court of New Jersey granted certiorari to review.

Rule of Law

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Issue

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Holding and Reasoning (Pashman, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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