Many divorce cases must address such issues as custody, visitation rights and spousal support or alimony payments. Although modern divorce statistics indicate that fewer than ten percent of divorces even consider spousal support or alimony during their proceedings, it still exists. Though it might be referred to as "maintenance" and "palimony", all spousal support is generally provided to the spouse who earns less or no income than the other. In earlier days it was strictly designed to provide a wife with enough income to live on following a divorce. In 1979, however, the Supreme Court determined that spousal support and alimony was a gender-neutral subject and should be granted to either spouse if they had financial need or hardship. In order for any ruling on spousal support a couple must either be legally separated or in the process of getting divorced.