Before 1950, courts would routinely award the wives, or ?“homemakers" lifetime spousal maintenance, unless the wife had misbehaved, committed adultery, or abandoned the marriage. At that time, most married women were unemployed and totally dependent on their spouses for support.

After the women's liberation movement, judges' attitudes toward spousal maintenance changed, and the awards dried up. This was particularly difficult for the fifty-five-year-old woman who had never worked outside the home. A judge was likely to give her $400 a month support for ten years, even if her spouse could afford to pay substantially more. The harsh results of these court decisions led to yet another turnaround. Today courts are again awarding lifetime spousal maintenance to spouses who have been career homemakers, and the awards are usually sufficient to enable these dependent spouses to meet their financial needs.