In McDougal v. McDougal, 451 Mich 80, 87; 545 NW2d 357 (1996), the Court reiterated the standard of review in divorce actions: In deciding a divorce action, the circuit court must make findings of fact and dispositional rulings. On appeal, the factual findings are to be upheld unless they are clearly erroneous. A dispositional ruling, however, "should be affirmed unless the appellate court is left with the firm conviction that it was inequitable" In McDougal, the parties were married eight years, the third marriage for each, the plaintiff wife had a Ph.D. in education and was earning $ 46,000 yearly, and the defendant husband was a retired engineer who worked as a private inventor. The trial court found that the defendant husband caused the breakdown of the marriage because he broke his promise that the couple would try to have children, made a unilateral determination that the parties would file separate tax returns, assaulted his wife and tried unsuccessfully to divert to his daughter some patent-related earnings which were received after the complaint was filed. The court awarded substantial assets to the wife, including patent rights and patent royalties, and this Court affirmed. In reversing, the Supreme Court referred to its prior opinions in both Sands and Sparks, again reiterating that "fault is an element in the search for an equitable division - - it is not a punitive basis for an inequitable division." McDougal, supra, at 90. The Court's review of the factors led it to conclude that the trial court's division was inequitable. Id., at 90-91.