
Quoting
pg1067
I'm not entirely sure what you're asking -- i.e., what "it" refers to when you talk about "citing it." The idea that, for a non-"long term" marriage (i.e., a marriage that lasted less than 10 years), spousal support "should be" ordered for half the length of the marriage is nothing but a rule of thumb. There is no law that says that. There may be case authority about this.
However, you wrote that you're filing a motion to terminate spousal support, which must mean that you're already divorced and some period of time has passed since your divorce judgment was entered. What does your divorce judgment say about when spousal support terminates? It should specify that spousal support is payable for some period of time. However, if it wasn't properly drafted, it may say nothing. Who drafted the divorce judgment, and is the divorce judgment based on a marital settlement agreement between you and your ex-spouse? If your divorce judgment is silent about when spousal support terminates, an argument after the fact that it ought to terminate for no reason other than the passage of some period of time isn't going to be persuasive. If your or the court's intent was that spousal support should terminate after 3.5 years, why wasn't that mentioned in the divorce judgment? If, in fact, the divorce judgment is silent about this, you're likely to have to make a fact-based argument that the former spouse receiving the support no longer needs it.
Bad assumption. I suggest you either hire a local family law attorney or spend some quality time at the county law library with The Rutter Group's Family Law practice guide.