The defendant in a divorce action was determined to be disabled by the Social Security Administration. Relying on Gilligan v. Gilligan, 428 N.J. Super. 69 (Ch. Div. 2012), the Appellate Division held that the SSA’s determination alone was insufficient to prove a disability. The Appellate Division abrogated Gilligan to the extent that it conflicts with Golian v. Golian, 344 N.J. Super. 337 (App. Div. 2001), wherein the Appellate Division held that the SSA’s determination that a person is disabled was prima facie evidence of the disability.