Prahl v. Prahl: When Divorce Leaves Spousal Maintenance Questions—and Answers—Up to the Judge

When Karen and Michael Prahl stood before the court to finalize their divorce, they were not just ending a marriage—they were facing uncertain futures, each wondering what their next chapter would look like.

Karen may have felt a sense of fear. Like many spouses who had relied on their partner’s income, she had questions about stability: Would she be able to cover rent? Could she support herself? Would she need to start over entirely? Michael, on the other hand, may have worried about how much financial support the court would expect from him—and for how long. Would he be ordered to pay indefinitely? Would it be fair?

These kinds of concerns are common in divorce—but when it comes to spousal maintenance, the law doesn’t offer clear-cut answers. Instead, it offers something else: judicial discretion.

That’s what made their case, Prahl v. Prahl, so important. At the heart of their dispute was the question of how much maintenance Karen would receive, and for how long. The trial court made its decision based on the facts presented—Karen’s needs, Michael’s ability to pay, and the standard of living they had during the marriage. But Michael appealed, arguing that the judge had made a mistake.

The Minnesota Court of Appeals disagreed. It upheld the district court’s decision and, in doing so, emphasized a key legal truth: judges in Minnesota have wide discretion when deciding spousal maintenance. Unless a judge clearly abuses that discretion—by ignoring the facts, applying the law incorrectly, or making a decision that no reasonable person could support—the appellate courts will usually stay out of it.

That’s because the law recognizes how fact-sensitive these decisions are. Every couple’s financial story is different. One spouse might have paused their career to raise children. Another might be close to retirement. A medical issue might limit someone’s ability to work. These personal details matter—and they’re often best understood by the trial judge who hears the evidence firsthand.

Under Minnesota Statutes section 518.552, a judge may grant maintenance. That word—“may”—is powerful. It tells us that awarding maintenance isn’t automatic. It’s a choice, guided by multiple factors: whether a spouse can meet their reasonable needs, whether they can become self-supporting, and how long that might take. These questions don’t always have black-and-white answers. And that’s where discretion comes in.

The appellate court in Prahl pointed out that it won’t substitute its judgment just because it might have decided differently. Unless the lower court “abused its discretion,” the ruling stands. This standard is difficult to overcome—by design. It protects the principle that the trial court, not the appellate court, is in the best position to weigh credibility and judge fairness.

For Karen and Michael, this meant that the trial court’s original maintenance order remained in place. The judge’s decision—rooted in statutory authority and factual analysis—was respected.

But for divorcing spouses across Minnesota, Prahl v. Prahl serves as a quiet but meaningful reminder: when it comes to spousal maintenance, the outcome can depend not just on the law, but on who is interpreting it. Judicial discretion is not a loophole—it’s a recognition of the human complexity in every divorce.

Citations

• Prahl v. Prahl, 627 N.W.2d 698, 702 (Minn. Ct. App. 2001) (holding that decisions on spousal maintenance are reviewed for abuse of discretion).
• Minn. Stat. § 518.552, subd. 1 (2024) – The court may grant spousal maintenance if a spouse lacks sufficient property or is unable to provide self-support through appropriate employment.
• See also Minn. Stat. § 518.552, subds. 2–3 – Outlining factors for amount and duration of maintenance, including standard of living, duration of the marriage, and the age and condition of the spouse seeking support.