In Re Marriage of Doerr v. Doerr
Granting $100,000 lump sum payment due to hardship was not appropriate exercise of discretion. Court found that wife needed payment to achieve standard of living, not to avoid privation.
In Re Marriage of Popp v. Popp
Hardship redefined: (1) financial deprivation or difficulty (2) not essential needs only.
Asbeck v. Asbeck
Hardship exception is a discretionary finding, not a factual determination.
Rosenberg v. Rosenberg
Trial court not required to award wife some of husband’s non-marital property to alleviate a hardship where the court awarded her greater share of the marital property.