STEINER VS. STEINER (FM-07-2818-18, ESSEX COUNTY AND STATEWIDE) (A-2440-20)
After sixty-three years of marriage, plaintiff Sylvia Steiner commenced this divorce action. At the conclusion of a bifurcated trial for the sole purpose of resolving the parties' dispute about whether there were grounds for divorce, the trial judge found irreconcilable differences and entered a judgment of divorce. In appealing, defendant David Steiner argued, among other things, that bifurcation should not have been permitted and that the trial judge erred in finding irreconcilable differences. The court affirmed, holding that what constitutes irreconcilable differences varies from couple to couple and that the judge's determination that this couple's differences were irreconcilable and had endured for six months, as required by N.J.S.A. 2A:34-2(i), was entitled to deference. The court also held that the presiding judge did not abuse his discretion in bifurcating the cause of action from the parties' equitable distribution issues because of both the parties' ages and judicial economy, considering that a potential ruling on the cause of action in defendant's favor would negate the need for a time-consuming and costly trial on the parties' extensive equitable distribution issues.
