February 27, 2023 – Re-Partnering and the SSAGs

“Simply applying the ranges in the SSAGs may not be appropriate in a re-partnering case. The court must first analyze the specific facts of the case to assess what a reasonable quantum and duration of support should be: Gray v. Gray, 2014 ONCA 659, 122 O.R. (3d) 337, at paras. 44 and 45.

The authors of the SSAGs, Professors Rogerson and Thompson, conclude that the outcomes in cases involving a recipient’s remarriage or re-partnering are not predictable enough to construct a formula to calculate what the effect on the ranges should be. However, the SSAGs can be a starting point in the discretionary analysis and an indicator of the reasonableness of a support award: Zacharias v. Zacharias, 2015 BCCA 376, 80 B.C.L.R. (5th) 54, at para. 62.”

            Politis v. Politis, 2020 ONSC 1306 (CanLII) at 115-116