Lalumiere v. Lalumiere
In Lalumiere v. Lalumiere, 149 Vt. 469, 544 A.2d 1170 (1988), the Court reversed a spousal maintenance award because the receiving spouse did not request it and the matter was not an issue at trial. 149 Vt. at 472, 544 A.2d at 1172.
Therefore, husband had no notice or opportunity to present evidence or argument on the matter. Id.