Supreme Court Upholds Trial Court’s Denial of Alimony to Help Husband Transition to Single Life

December 3, 2012

In a unanimous opinion, the Tennessee Supreme Court reversed the Court of Appeals and reinstated the trial court’s judgment that denied a husband’s request for transitional alimony to cushion his adjustment to single life.

The case involved Patricia Carlene Mayfield and Phillip Harold Mayfield, who married in 1992, separated in 2008 and divorced in 2009. Throughout the couple’s seventeen-year marriage, Ms. Mayfield worked as a pharmacist and earned as much as $156,000 annually prior to the couple’s divorce. Although he had worked in the tool-and-die industry prior to the marriage, Mr. Mayfield worked full time in an unprofitable cattle farming operation during the marriage and assumed primary responsibility for the care of their children.

The trial court record contains evidence that Mr. Mayfield physically and verbally abused Ms. Mayfield on multiple occasions prior to Ms. Mayfield fleeing the marital home with the couple’s two children. She later filed for divorce and Mr. Mayfield requested alimony.

The trial court granted Ms. Mayfield a divorce, but denied Mr. Mayfield’s alimony request. The court specifically found that Mr. Mayfield would be able to maintain the same standard of living after the divorce as the parties enjoyed during the marriage, since he received the marital home and other assets as part of the property division.

The trial court explained that Mr. Mayfield was willfully underemployed, had an earning capacity of $45,000 per year, and could earn a living for himself because he had been awarded the 150-acre farm, a house, furnishings, a farm truck, and cash in the divorce

The trial court also found that Mr. Mayfield’s abuse of Ms. Mayfield put him comparatively more at fault for causing the breakup of the marriage, that he had no substantial financial obligations, needed no further extensive educational training, and could return to the tool-and-die industry by completing a brief class on the operation of certain machines.

Mr. Mayfield appealed. The Court of Appeals reversed the trial court’s judgment and awarded Mr. Mayfield $2000 per month in transitional alimony for 36 months.

The Tennessee Supreme Court reversed the Court of Appeals and reinstated the trial court’s judgment denying alimony. In the opinion, the Court cited the “broad discretion” Tennessee’s trial courts have “to determine whether spousal support is needed and, if so, to determine the nature, amount, and duration of the award.” The Court cautioned that an appellate court’s role is “not to second guess the trial court or to substitute its judgment for that of the trial court, but to determine whether the trial court abused its discretion in awarding, or refusing to award, spousal support.” The Court concluded that the trial court did not abuse its discretion in denying Mr. Mayfield alimony.

Read Mayfield v. Mayfield, authored by Justice Cornelia A. Clark, here.