Alimony, also called spousal support or spousal maintenance, may be awarded when one spouse demonstrates financial need and the other has the ability to pay. Below is a comprehensive guide to alimony laws in each US state and Canadian province, including calculation methods, duration limits, and factors courts consider.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in Alabama divorces based on financial need and the other spouse's ability to pay. Alabama recognizes interim, rehabilitative (up to 5 years), and periodic alimony (generally limited to the length of the marriage). For marriages of 20 years or more, there is no statutory time limit on periodic alimony eligibility (Ala. Code §30-2-57).
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Alaska courts may award spousal support (the state's term for alimony) under AS §25.24.160(a)(2). The three types are temporary, rehabilitative, and reorientation support. There is no fixed formula — the court considers factors like marriage length, each spouse's earning capacity, health, financial condition, and standard of living. Permanent alimony is rare; Alaska courts generally prefer limited-duration support or adjusting property division to address economic disparities.
- •Calculation method: Advisory guidelines
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: community property
Yes, spousal maintenance (alimony) may be awarded in Arizona divorces, but it is not automatic. The requesting spouse must first show eligibility under A.R.S. § 25-319(A) — for example, by demonstrating insufficient property, inadequate earning ability, or significant career sacrifices made during the marriage. If eligible, the court determines the amount and duration using the Spousal Maintenance Guidelines and 13 statutory factors, with the goal of helping the recipient become self-sufficient.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, alimony may be awarded in Arkansas divorces to either spouse under Ark. Code Ann. § 9-12-312. The court considers the need of one spouse and the ability of the other to pay as the primary factors. Rehabilitative alimony (temporary, to allow self-sufficiency) is the most common type, though permanent alimony may be awarded in long marriages where the recipient has limited earning capacity. Alimony automatically terminates upon the recipient's remarriage, cohabitation in an intimate relationship, or death of either party.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: community
California spousal support (Family Code § 4320) is based on the marital standard of living. For marriages under 10 years, support typically lasts half the marriage length. For marriages over 10 years, support may be permanent. Courts consider earning capacity, age, health, and each party's financial resources.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, Colorado courts may award spousal maintenance (alimony) under C.R.S. §14-10-114 when one spouse needs financial support and the other has the ability to pay. For marriages lasting at least three years with combined annual income under $240,000, advisory guidelines provide a formula-based starting point for the amount and duration of maintenance. The court retains discretion to deviate from the guidelines based on the specific circumstances of the case.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, alimony may be awarded in Connecticut divorces under Conn. Gen. Stat. §46b-82. The court considers factors including the length of the marriage, each party's income and earning capacity, age, health, the causes for the dissolution (fault), and other relevant circumstances. Connecticut recognizes three types of alimony: temporary (during proceedings), rehabilitative (time-limited), and permanent (until death or remarriage).
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in Delaware if the requesting spouse can demonstrate dependency — that they lack sufficient property and income to meet their reasonable needs and are unable to support themselves through appropriate employment (13 Del.C. §1512(b)). Alimony duration generally cannot exceed 50% of the length of the marriage, although marriages lasting 20 years or more have no time cap on eligibility.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, alimony may be awarded in DC divorces if the court deems it just and proper under D.C. Code § 16-913. The court considers factors including each party's ability to be self-supporting, the duration of the marriage, the standard of living during the marriage, and the history of any abuse. Alimony can be indefinite or term-limited based on the circumstances.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable
Florida Statute § 61.08 authorizes bridge-the-gap, rehabilitative, and durational alimony based on need and ability to pay. As of 2023, permanent alimony was eliminated. Courts consider the marriage duration, standard of living, each party's financial resources, and earning capacity when setting alimony amounts and duration.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: Yes
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Alimony may be awarded in Georgia based on one spouse's need and the other's ability to pay, per O.C.G.A. § 19-6-1 and § 19-6-5. There is no formula; the court considers factors like the marriage's duration, standard of living, and each party's financial resources. Notably, a spouse whose adultery or desertion caused the separation is barred from receiving alimony.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony (called maintenance) may be awarded to either spouse under HRS §580-47. The court considers factors including the standard of living during the marriage, duration of the marriage, each spouse's financial resources and earning capacity, and the receiving spouse's ability to become self-supporting. Marital misconduct is not a factor in determining alimony in Hawaii.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Generally not available
- •Property division: community property
Yes, but spousal maintenance is not automatic in Idaho. Under Idaho Code §32-705, the requesting spouse must prove they lack sufficient property to meet their reasonable needs AND are unable to support themselves through employment. If both conditions are met, the court considers factors including the marriage duration, each spouse's age and health, earning capacity, and marital fault to determine the amount and duration of any award.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, spousal maintenance (Illinois's term for alimony) may be awarded to either spouse under 750 ILCS 5/504. For couples with combined gross income under $500,000, the amount is calculated as 33.33% of the payor's net income minus 25% of the payee's net income, with a cap ensuring the payee does not receive more than 40% of combined net income. Duration depends on the length of the marriage, with longer marriages resulting in longer maintenance periods, and marriages of 20+ years potentially qualifying for indefinite maintenance.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Indiana uses the term 'spousal maintenance' rather than alimony, and it is awarded only in limited circumstances under IC § 31-15-7-2: (1) when a spouse is physically or mentally incapacitated, (2) when a spouse cares for an incapacitated child and lacks sufficient property, or (3) as rehabilitative maintenance capped at three years. Indiana is one of the most restrictive states for spousal support.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Iowa courts may award spousal support (alimony) to either spouse. Iowa recognizes three main types: traditional (potentially indefinite for long marriages), rehabilitative (temporary, to help a spouse become self-supporting), and reimbursement (to compensate a spouse who supported the other's education or career) (Iowa Code §598.21A). The amount and duration are determined case by case based on financial need, ability to pay, marriage length, and other factors.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, Kansas courts may award spousal maintenance under K.S.A. § 23-2902 in an amount deemed 'fair, just and equitable under all of the circumstances.' There is no set formula — the court considers factors like the length of the marriage, each party's earning capacity, and financial needs. Court-ordered maintenance is capped at 121 months (about 10 years), with the possibility of a one-time extension if a timely motion is filed before the original term expires.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Spousal maintenance (Kentucky's term for alimony) may be awarded under KRS §403.200 if the requesting spouse lacks sufficient property to meet their reasonable needs and is unable to support themselves through appropriate employment. The court considers factors including the standard of living during the marriage, duration of the marriage, age, health, and each party's financial resources. Maintenance may be temporary, rehabilitative, or in rare cases, permanent.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Generally not available
- •Property division: community property
Yes, Louisiana courts may award both interim and final periodic spousal support. To receive final periodic support, the requesting spouse must be free from fault prior to filing for divorce and must demonstrate financial need, per Civil Code Article 112. The amount generally cannot exceed one-third of the obligor's net income, though exceptions exist in domestic abuse cases.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, Maine courts may award spousal support (alimony) under 19-A M.R.S.A. §951-A. There are five types: general, transitional, reimbursement, nominal, and interim support. The court considers factors including the length of the marriage, each party's income and earning potential, age, health, and contributions to the marriage. General support is presumptively unavailable for marriages under 10 years.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, alimony may be awarded in Maryland divorces. The most common type is rehabilitative alimony — a fixed-term award designed to help the dependent spouse become self-supporting. Indefinite alimony is rare and reserved for situations where the dependent spouse cannot become self-supporting or where the parties' standards of living would be unconscionably disparate. The court considers factors under Md. Code, Family Law § 11-106, and alimony must be requested before the divorce is finalized.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in Massachusetts under the Alimony Reform Act (Mass. Gen. Laws ch. 208, §§ 48–55). The court considers factors including marriage length, income disparity, age, health, and contributions to the marriage. The amount generally should not exceed 30–35% of the difference between the spouses' gross incomes, and duration is capped based on the length of the marriage.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: Yes
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Michigan courts may award spousal support (alimony) under MCL §552.23(1) when the property division is insufficient for a spouse's suitable support. There is no fixed formula; instead, courts consider factors such as the length of marriage, each party's earning ability, age, health, standard of living, contributions to the marriage, and fault. Support may be temporary, periodic, permanent, or paid in a lump sum.
- •Calculation method: Advisory guidelines
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Minnesota courts may award spousal maintenance (alimony) under Minn. Stat. §518.552 when a spouse lacks sufficient income or property to meet reasonable needs. Following the 2024 reforms (effective August 1, 2024), the law now provides clearer guidelines distinguishing between 'transitional' and 'indefinite' maintenance, with presumptions tied to the length of the marriage.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony is available in Mississippi and may be awarded to either spouse based on need and the other spouse's ability to pay. Courts consider the twelve Armstrong factors (from Armstrong v. Armstrong, 618 So.2d 1278 (Miss. 1993)), including income, earning capacity, length of the marriage, standard of living, health, and fault. Common types include rehabilitative alimony, periodic alimony, lump-sum alimony, and reimbursement alimony.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Missouri courts may award spousal maintenance (alimony) under RSMo §452.335 if the requesting spouse lacks sufficient property to meet reasonable needs and cannot become self-supporting through appropriate employment. The court considers factors such as the duration of the marriage, each spouse's earning capacity, the marital standard of living, and the conduct of the parties. Maintenance may be temporary, rehabilitative, or in rare cases, permanent.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, spousal maintenance (alimony) may be awarded in Montana under MCA § 40-4-203. However, it is not automatic — the requesting spouse must demonstrate that they lack sufficient property for their reasonable needs and are unable to support themselves through appropriate employment. The court considers factors such as the standard of living during the marriage, its duration, each spouse's financial resources, and the time needed to obtain job training or education.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Alimony may be awarded in Nebraska but it is not automatic and is not guaranteed. Under Neb. Rev. Stat. §42-365, the court considers factors such as the duration of the marriage, each spouse's contributions and earning capacity, and whether career or educational opportunities were interrupted. Most alimony awards are rehabilitative in nature, and they generally terminate upon the death of either party or remarriage of the recipient.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: community property
Yes, alimony may be awarded in Nevada divorces under NRS 125.150, but it is not automatic. The court considers eleven statutory factors, including the length of the marriage, each spouse's income and earning capacity, the standard of living during the marriage, and each spouse's contributions as a homemaker. Nevada has no fixed alimony formula; the court awards what it deems 'just and equitable' based on the specific circumstances of each case.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Alimony may be awarded in New Hampshire under RSA 458:19-a if the requesting spouse demonstrates need and the other spouse has the ability to pay. The statutory formula sets the amount at 23% of the difference between the parties' gross incomes, with a maximum duration of 50% of the length of the marriage. The court may adjust both amount and duration based on special circumstances.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in New Jersey divorces under N.J.S.A. 2A:34-23. The court considers 14 statutory factors, including each party's actual need and ability to pay, the duration of the marriage, the standard of living during the marriage, and each party's earning capacity. Under the 2014 alimony reform, four types may be awarded: open durational alimony (generally for marriages of 20+ years), limited duration alimony (capped at the length of the marriage for marriages under 20 years), rehabilitative alimony, and reimbursement alimony.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: community property
Yes, New Mexico courts may award spousal support (alimony) to either spouse based on demonstrated financial need and the other spouse's ability to pay (NMSA 1978, § 40-4-7). Types of support include rehabilitative, transitional, lump-sum, and indefinite-duration alimony. The court considers factors such as the length of the marriage, each spouse's earning capacity, the marital standard of living, and contributions as a homemaker. For marriages of 20 years or more, the court retains jurisdiction over spousal support unless the decree specifically provides otherwise.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable
New York spousal maintenance (DRL § 236-B(6)) uses a formula based on both spouses' incomes capped at $228,000 for the higher earner. Duration guidelines: 15-30% of marriage length for marriages under 15 years, 30-40% for 15-20 years, 35-50% for 20+ years. Courts can deviate based on need, earning capacity, and health.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in North Carolina. Under N.C. Gen. Stat. §50-16.3A, a 'dependent spouse' may receive alimony from a 'supporting spouse' if the court finds an award is equitable. Marital misconduct plays a critical role: if the supporting spouse committed illicit sexual behavior, alimony must be awarded; if the dependent spouse did so, alimony must be denied. The court considers sixteen factors including income, earning capacity, marriage duration, and standard of living.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, spousal support may be awarded in North Dakota divorces under N.D.C.C. § 14-05-24.1. The court may order temporary, rehabilitative, or permanent support for a limited period of time if the requesting spouse lacks sufficient income or property to meet reasonable needs and the other spouse can pay without undue hardship. There is no formula — the court uses the Ruff-Fischer guidelines to determine amount and duration.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, Ohio courts may award spousal support (alimony) to either spouse under O.R.C. §3105.18. There is no formula — the court considers factors such as each party's income, earning ability, the duration of the marriage, the standard of living during the marriage, and each spouse's contributions. Support may be temporary or long-term, and can be paid as a lump sum or in periodic installments.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in Oklahoma divorces, but it is not automatic. The court evaluates the requesting spouse's demonstrated financial need and the other spouse's ability to pay. There is no fixed formula; the court considers factors including the length of the marriage, each spouse's earning capacity, the marital standard of living, and the overall property division. Rehabilitative alimony for a limited period is most common.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, Oregon courts may award spousal support (alimony) in three forms: transitional support (for education/job reentry), compensatory support (reimbursing contributions to the other spouse's career), and spousal maintenance (for ongoing standard-of-living support). The court considers factors outlined in ORS §107.105(1)(d), including the length of the marriage, each party's income and earning capacity, health, age, and standard of living during the marriage. There is no fixed formula.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Pennsylvania courts may award alimony, but only when the court finds it is necessary under 23 Pa.C.S. § 3701. Alimony is not automatic and is determined by 17 statutory factors including relative earnings, the duration of the marriage, each spouse's health and age, and contributions to the other's education or career. Alimony may be awarded for a definite or indefinite duration and terminates upon the recipient's remarriage or cohabitation.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, alimony may be awarded in Rhode Island divorces under R.I. Gen. Laws § 15-5-16, but it is not automatic. The court considers factors including the length of the marriage, each spouse's health, age, income, employability, and the needs and liabilities of each party. Rhode Island alimony is primarily rehabilitative — designed to help the recipient become self-sufficient — though indefinite alimony may be awarded in cases involving advanced age, disability, or prolonged absence from the workforce.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in South Carolina divorces under S.C. Code § 20-3-130. The court considers 13 factors including the duration of the marriage, each spouse's earning capacity, the marital standard of living, and marital misconduct. There are four types: periodic, lump-sum, rehabilitative, and reimbursement alimony. Importantly, a spouse who commits adultery is barred from receiving alimony under South Carolina law.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony may be awarded in South Dakota divorces. Under SDCL § 25-4-41, the court may order one spouse to pay support to the other for life or a shorter period. Courts consider factors such as the length of the marriage, each spouse's earning capacity, their ages and health, financial conditions after property division, and responsibility for the marriage's breakdown.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Tennessee courts may award alimony in divorce cases under T.C.A. §36-5-121. There are four types: rehabilitative alimony (preferred, to help a spouse become self-sufficient), alimony in futuro (long-term/permanent support), transitional alimony (short-term adjustment assistance), and alimony in solido (lump sum). The court considers factors such as each spouse's earning capacity, needs, duration of marriage, and the property division in determining whether alimony is appropriate.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: community
Texas spousal maintenance (Family Code § 8.051) is only available after marriages of 10+ years if the requesting spouse cannot meet minimum needs. Maximum payment is $5,000/month or 20% of the paying spouse's gross monthly income. Duration is capped at 5 years (10-20 year marriages), 7 years (20-30 years), or 10 years (30+ years).
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Alimony may be awarded in Utah divorces but is not automatic. Under Utah Code § 81-4-502, the court considers the recipient's financial needs, earning capacity, the payor's ability to pay, the length of the marriage, the standard of living during the marriage, and other relevant factors. As a general rule, alimony cannot last longer than the length of the marriage, and it terminates automatically upon the recipient's remarriage or death.
- •Calculation method: Court discretion
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, Vermont courts may award spousal maintenance (alimony) under 15 V.S.A. § 752 if the requesting spouse lacks sufficient income or property to meet their reasonable needs and cannot achieve self-support at the marital standard of living. Maintenance can be rehabilitative (short-term) or long-term, and the amount and duration are determined by the court based on factors such as the length of the marriage, each party's financial resources, and the standard of living during the marriage.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, Virginia courts may award spousal support (alimony) under Virginia Code § 20-107.1. The court considers factors including the duration of the marriage, each party's financial resources, the standard of living during the marriage, and the circumstances that led to the divorce. Notably, a spouse found guilty of adultery is generally barred from receiving permanent spousal support, unless denial would cause manifest injustice.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: community property (just and equitable division)
Yes, Washington courts may award spousal maintenance (alimony) to either spouse under RCW §26.09.090. The court considers factors including each spouse's financial resources, the standard of living during the marriage, the duration of the marriage, age and health of the requesting spouse, and the paying spouse's ability to pay. There is no fixed formula — awards are based on the court's discretion given the specific circumstances of each case.
- •Calculation method: Court discretion
- •Fault considered: Yes
- •Permanent alimony: Available in some cases
- •Property division: equitable distribution
Yes, alimony (called spousal support in West Virginia) may be awarded to either spouse upon divorce under W. Va. Code §48-8-101, provided the spouses are living separate and apart. The court recognizes four types: permanent, temporary (pendente lite), rehabilitative, and spousal support in gross. The court considers up to 20 factors under §48-6-301, including income disparity, duration of the marriage, earning capacity, and marital fault, to determine the amount and duration of support.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Available in some cases
- •Property division: community property
Yes, spousal maintenance (alimony) may be awarded to either party under Wis. Stat. §767.56. There is no set formula; instead, the court considers factors including the length of the marriage, each party's earning capacity, age, health, educational background, contributions to the other's career, and the standard of living during the marriage. Maintenance may be awarded for a limited duration or indefinitely, particularly in long-term marriages.
- •Calculation method: Formula-based (statutory guidelines)
- •Fault considered: No
- •Permanent alimony: Generally not available
- •Property division: equitable distribution
Yes, alimony (spousal support) may be awarded in Wyoming divorces. Under Wyo. Stat. §20-2-114, the court may decree 'reasonable alimony' to either party, considering the paying spouse's ability to pay and the requesting spouse's financial needs. There is no fixed formula — the court has broad discretion and considers factors like the length of the marriage, earning capacity, and each party's contributions to the marriage.