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Self, 861 S.W.2d at 361. The Court explained that under
Tennessee law, the only situation justifying long-term support
and maintenance would be where there was economic disadvantage to
one of the parties and rehabilitation was “not feasible.” Thus,
the trial court’s finding that Mrs. Self was eligible for
rehabilitation precluded the awarding of open-ended, long-term
support in the form of alimony in futuro. Thus the Court found
the alimony in Self to be unmodifiable. See also Campbell v.
Campbell, 832 S.W.2d 31, 32 (Tenn. Ct. App. 1991) (unmodifiable
even if rehabilitation prevented by onset of serious illness).
Isbell and Self indicate that, for a 1992 divorce, alimony
like the payments here--fixed in amount and for a definite term--
would be classified as alimony in solido even if made with a
rehabilitative purpose. And, as a general rule, an obligation to
pay alimony in solido does not end with the death of the payee
spouse. Isbell, 816 S.W.2d at 739. Applying this general rule
to the stipulated facts of this case strongly suggests that even
if Rogers is right in characterizing the disputed payments as
rehabilitative alimony, he would still lose because that would
just make them alimony in solido.
The discerning reader, though, would have noted that this
characterization is true only as a default rule--in Self itself,
the Court ordered the payments to stop on the death of Mrs. Self.
And the parties here argue about whether a similar intent can be
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