In re the Marriage of Valente

¶1 A trial court has broad discretion to award maintenance to address the medical needs of a spouse, but reserving jurisdiction to revisit maintenance if the disease worsens is problematic. When the trial court finds only that a spouse “may” incur future medical ex*820penses and rehabilitation costs, it is an abuse of discretion to make a “placeholder” award of nominal maintenance in order to reserve jurisdiction.

¶2 Here, the trial court awarded Fukiko Valente (Nao) nominal maintenance of $100 per month from the time she turns 72 years old until the death of either party or her remarriage. The…