When distributing the marital estate in this case, the trial court relied on this Court's decision in Webb v. Webb, No. W2021-01227-COA-R3-CV, 2023 WL 568331 (Tenn. Ct. App. Jan. 27, 2023). A divorce case, Webb involved what this Court determined to be a short-term marriage of six years' duration at the time of trial.
Under this version of the statute, "the court's decision must be guided by consideration of the relevant statutory factors." Webb v. Webb, No. W2021-01227-COA-R3-CV, 2023 WL 568331, at *4 (Tenn. Ct. App. Jan. 27, 2023), no perm. app. filed (citing Gonsewski v. Gonsewski, 350 S.W.3d 99, 113 (Tenn. 2011); Tenn. Code Ann. ยง 36-5-121(i)). The two most important considerations are need and ability to pay.
Here, the trial court thoroughly considered the applicable case law, the facts, and the equities of the parties in formulating its division of marital property; as such, we will not disturb its judgment on appeal. See Webb v. Webb, No. W2021-01227-COA-R3-CV, 2023 WL 568331 (Tenn. Ct. App. Jan. 27, 2023) (affirming 87/13 percent division of marital assets where one party brought significantly more separate property to the short marriage and contributed more to the principal joint asset); Long v. Long, 642 S.W.3d 803, 828 (Tenn. Ct. App. 2021) (finding that the trial court's consideration of the statutory factors "was consistent with logic and reason and that the result to these parties was equitable" although the trial court's 51/49 percent distribution was not mathematically equal), perm. app. denied (Tenn. Feb. 10, 2022); Prichard, 2023 WL 2726776, at *12 (affirming 59.5/40.5 percent division of marital property where "trial court did not abuse its broad discretion" in fashioning the distribution); Larsen-Ball, 301 S.W.3d at 236-37 (affirming 60/40 percent division where it was "apparent from the trial court's order that the trial court considered the relevant factors").
In this Opinion, we apply the version of the relevant statute, Tennessee Code Annotated section 36-4-121, in effect at the time Husband filed the petition for divorce in September 2020. See Webb v. Webb, No. W2021-01227-COA-R3-CV, 2023 WL 568331, at *2 n.2 (Tenn. Ct. App. Jan. 27, 2023).