Divorce; Property distribution; Sparks v Sparks; Spousal support; Attorney fees; MCR 3.206(D)(2)(a) & (b)

The court rejected plaintiff-ex-husband’s argument that “the trial court’s property division was inequitable.” It vacated the spousal support award for defendant-ex-wife solely as to the amount and “remanded for the trial court to provide proper and sufficient findings of fact to justify the particular amount of spousal support it decides should be awarded.” It also vacated the award of attorney fees to defendant and remanded “for the trial court to address the issue again and make proper findings of fact that will facilitate meaningful appellate review.” As to the property division, the court found that a “review of the record, along with the deference afforded to the trial court’s assessment of witness credibility, does not lead to a definite and firm conviction that the trial court made a mistake in finding plaintiff was primarily at fault for the breakdown of the marriage due to his relationship with [nonparty-K], and plaintiff has failed to establish this finding was clearly erroneous.” He next argued “that the trial court clearly erred by finding him at fault for the breakdown of the marriage based on the financial support he provided to” the parties’ adult daughter (A) “because, according to plaintiff, the parties always supported [A] throughout the marriage and defendant was aware of this financial support.” The court found that while “there was somewhat conflicting evidence on this point, the evidence does not lead to a definite and firm conviction that the trial court made a mistake.” As to whether the property distribution was equitable, the court held that contrary “to plaintiff’s assertions, the trial court considered the relevant factors as applicable to the facts and circumstances of the” case. The trial court “also made specific findings of fact regarding the relevant factors.” And the court noted that “there is no rigid framework or mathematical formula for applying the factors.” The real focus of plaintiff’s appellate argument was his claim “that the trial court placed undue weight on the fault findings to reach an inequitable, rather than an equitable, property distribution.” The court concluded that while “the trial court clearly considered fault as a factor, its decision was not based solely on that factor.” Plaintiff did not show “that the trial court placed excessive weight on the issue of fault or that [it] ordered an inequitable property division.” But as to plaintiff’s challenges to the trial court’s spousal support award, the court found that it was “unclear how the trial court arrived at the amount it awarded, making it appear to be an arbitrarily selected amount.” Affirmed in part, vacated in part, and remanded.