This Note first analyzes the Stevens court's opinion and concludes that it fails to give sufficient direction on how to determine the amount of the alimony award in order to sufficiently compensate the supporting spouse. Second, this Note explores the ways in which courts in other jurisdictions have attempted to compensate the supporting spouse. Finally, this Note proposes two alternative methods of valuing the supporting spouse's contribution. One method applies if the court, as in Stevens v. Stevens, holds that contribution toward a technical degree is not divisible marital property but should be considered when awarding alimony. The second method, and perhaps the more equitable one, can be used to determine an award based on restitution limited to direct expenditures and cost of lost opportunity.
"A Professional Degree Is Not Marital Property Upon Divorce: Stevens v. Stevens,"
Akron Law Review: Vol. 20
, Article 8.
Available at: http://ideaexchange.uakron.edu/akronlawreview/vol20/iss2/8