## Facts

- Husband and wife were married for 26 years and had one adult child.
- At trial, the wife (age 42) was unemployed and receiving temporary alimony; the husband (age 45) was employed and earned about $41,000 annually.
- The husband obtained a college degree during the marriage; the wife left school at age 16 when she married.
- The trial court found the wife’s sexual infidelity and desire to leave the marriage caused the marital breakdown.
- The trial court awarded the wife no alimony, $500 in attorney fees, and 25% of the marital estate, awarding 75% to the husband.
- The Court of Appeals reversed as to alimony (remanding for an evidentiary hearing) but affirmed the 75/25 property division.
- The Supreme Court granted review to address the role of fault in equitable distribution of marital assets.

## Issues

1. Whether marital fault remains a permissible consideration in dividing marital property after adoption of no-fault divorce.
2. Whether assigning controlling or disproportionate weight to fault renders a property division inequitable.
3. What analytical factors trial courts must consider in achieving an equitable property division, and how appellate courts review such rulings.

## Decision

- The Supreme Court held that marital misconduct remains relevant to property division, but it is only one factor and may not be given disproportionate weight.
- The Court concluded the 75/25 division was inequitable because the trial court overemphasized the wife’s fault and gave inadequate consideration to other equitable factors.
- The Court reversed approval of the property division and remanded for a new property-division hearing.
- The Court directed that the matter be reassigned to a different judge to avoid any appearance of impropriety.

## Legal Principles

- Michigan divorce property division seeks an equitable result, not necessarily an equal split, based on the parties’ individualized circumstances.
- Fault is a permissible factor in property division, but it cannot dominate the analysis or be assigned controlling weight.
- Trial courts must consider all relevant circumstances, including (non-exclusively): duration of marriage; each party’s contributions to the marital estate; age; health; life status; necessities and circumstances; earning abilities; past relations and conduct; and general principles of equity.
- Appellate review follows a two-step framework: (1) factual findings are reviewed for clear error; (2) the dispositional property ruling is reviewed for whether the appellate court is left with a firm conviction that the division was inequitable.

## Conclusion

The court required a new property division because the trial judge treated marital fault as effectively determinative, contrary to equitable-distribution standards that require balanced consideration of all relevant factors.


Sparks v. Sparks, 440 Mich. 141, 485 N.W.2d 893 (Mich. 1992)