When the Missouri Legislature passed the Divorce Reform Act in 1973 it was the first change in Missouri divorce law in ninety-five years. This Note will analyze the result reached in the instant decision as well as the practical implications the decision will have on numerous in gross awards being paid today. After outlining the statutory framework under which the court operated, this Note will briefly discuss the history of the application of in gross alimony awards and the divergent path that Missouri courts have taken, either terminating or sustaining the award upon the recipient spouse's remarriage. This Note will then discuss the implications of the Cates decision on past maintenance awards and make suggestions for structuring future ones.

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