In the case of Chin v. Merriot, the Supreme Judicial Court of Massachusetts addressed the issue of whether the provisions of the Alimony Reform Act of 2011 could be applied retroactively to modify an alimony obligation that was established in a separation agreement prior to the enactment of the Act. Chester Chin and Edith Merriot were divorced in 2011, and their separation agreement included a provision for Chin to pay alimony to Merriot. Chin later sought to terminate his alimony obligation, citing his attainment of full retirement age and Merriot’s cohabitation with another person as grounds for modification under the new Act. However, the court held that the retirement and cohabitation provisions of the Alimony Reform Act apply prospectively and do not affect alimony judgments entered before the Act’s effective date. Therefore, the court affirmed the dismissal of Chin’s complaint for modification, as he failed to demonstrate a material change in circumstances under the standards that existed prior to the Act. The decision emphasized that the Act’s provisions for termination of alimony based on retirement or cohabitation do not apply retroactively to judgments that predate the Act.