Patricia Carlene Mayfield v. Phillip Harold Mayfield
395 S.W.3d 108
| Tenn. | 2012Background
- Married 1992, separated 2008; 17-year marriage; two children aged eight and eleven at trial.
- Wife worked outside the home as a pharmacist, earning about $156,000 in 2008; Husband farmed full time with little other employment.
- Trial court granted divorce on Husband's inappropriate marital conduct, designated Wife primary residential parent, divided marital estate, and declined to award alimony to Husband.
- Court of Appeals affirmed custody and estate division, but reversed to award $2,000/month transitional alimony for 36 months.
- This Court granted review to determine if Court of Appeals erred in reversing the denial of transitional alimony; Court reinstates trial court's denial.
- Court held trial court did not abuse discretion in declining alimony; Court of Appeals' transitional alimony award reversed; other aspects affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly denied alimony to Husband | Mayfield; Husband lacks need for alimony | Mayfield; Husband needs transitional support to adjust | Trial court did not abuse discretion; no alimony. |
| Whether transitional alimony was warranted under the facts | Mayfield; Wife's income far exceeds Husband's and no need shown | Mayfield; Husband entitled to transitional alimony to bridge gap | Transitional alimony not warranted. |
| What standard governs reversal of alimony rulings on appeal | Mayfield; abuse of discretion standard applied | Mayfield; standard properly used | Appellate review affirmed, no error in standard applied. |
Key Cases Cited
- Gonsewski v. Gonsewski, 350 S.W.3d 99 (Tenn. 2011) (reaffirmed discretion in alimony determinations; emphasizes need and ability to pay factors)
- Bratton v. Bratton, 136 S.W.3d 595 (Tenn. 2004) (discretionary nature of spousal support; factors governing award)
- Henderson v. SAIA, Inc., 318 S.W.3d 328 (Tenn. 2010) (abuse-of-discretion standard in alimony decisions)
- Crabtree v. Crabtree, 16 S.W.3d 356 (Tenn. 2000) (multifactor analysis for alimony awards; supports deference to trial court)
- Engesser v. Engesser, 42 So.3d 249 (Fla. Dist. Ct. App. 2010) (describes transitional alimony as bridge-to-self-sufficiency)