In Alston v. Alston, 331 Md. 496, 504, 629 A.2d 70 (1993), a husband purchased a winning lotto ticket with an annuity value of over one million dollars a year-and-a-half after he and his wife had separated, but before they were divorced. The wife had initially filed, prior to the husband's winning of the lottery, a divorce action based on the couple's voluntary separation for over one year and did not seek either alimony or a monetary award. That action was pending in the Circuit Court for Baltimore City when the wife first learned that her husband had won the lottery. After learning of her husband's sudden stroke of fortune, the wife immediately dismissed that initial divorce petition. Approximately six months later, the wife filed a second complaint for absolute divorce, this time in the Circuit Court for Baltimore County, on the ground of adultery. She sought a monetary award representing a substantial part of her husband's lottery annuity. After granting the wife an absolute divorce based on the husband's adultery, the trial court granted the wife a monetary award of fifty percent of the yearly net distribution on the annuity. In Alston v. Alston, 85 Md. App. 176, 582 A.2d 574 (1990), the Court affirmed the trial court, holding that it had not abused its discretion in making the monetary award. The Court of Appeals reversed our decision, holding that the trial court erred. In Alston, 331 Md. at 507, the Court of Appeals explained why "in a case such as this the eighth factor should be given greater weight than the others" and faulted both the trial court and this Court for having "indicated that the eighth factor should not be given any more weight than any other factor." Heedful of Alston, Judge Nolan acknowledged that the eighth factor "should be given considerable weight." In a 23-page Opinion and Order, she made a detailed analysis of all of the factors listed in 8-205(b). She then engaged specifically in a detailed discussion of the eighth factor: 8. How and when specific marital property or interest in the pension, retirement, profit sharing, or deferred compensation plan, was acquired, including the effort expended by each party in accumulating the marital property or the interest in the pension, retirement, profit sharing, or deferred compensation plan or both. The defendant contends that this factor should be given considerable weight. The court in Alston stated that: ...generally in a case such as this the eight factor should be given greater weight than the others. Where one party, wholly through his or her own efforts, and without any direct or indirect contribution by the other, acquires a specific item of marital property after the parties have separated and after the marital family has, as a practical matter, ceased to exist, a monetary award representing an equal division of that particular property would not ordinarily be consonant with the history and purpose of the statute. .Alston, 331 Md. at 507. The Court of Appeals stated that "the eighth factor should be given greater weight than the others." The Court further noted, however, that the circumstances of each case will dictate when more emphasis on this factor is warranted. Id. In Alston, the Court emphasized factor eight because, where one party, wholly through his or her own efforts, and without any direct or indirect contribution by the other, acquires a specific item of marital property after the parties have separated and after the marital family has, as a practical matter, ceased to exist, a monetary award representing an equal division of that particular property would not ordinarily be consonant with the history and purpose of the statute. Alston, 331 Md. at 507. In Alston v. Alston, 331 Md. 496, 507, 629 A.2d 70 (1993), the Court of Appeals held that the trial court erred in failing to give this factor "considerable weight" in distributing the value of a lotto ticket that the husband purchased after separation: "Where one party, wholly through his or her own efforts, and without any direct or indirect contribution by the other, acquires a specific item of marital property after the parties have separated and after the marital family has, as a practical matter, ceased to exist, a monetary award representing an equal division of that particular property would not ordinarily be consonant with the history and purpose of the statute." The Court of Appeals cautioned against "succumbing to the temptation to divide the marital property equally ... our statute requires 'equitable' division of marital property, not 'equal' division." Indeed, "no hard and fast rule can be laid down, and ... each case must depend upon its own circumstances to insure that equity be accomplished...." Id. at 507. Nevertheless, the trial court must exercise its discretion in accordance with correct legal standards. Alston, 331 Md. at 504. In Alston, the trial court granted Mrs. Alston a divorce and also granted her a monetary award. In calculating the amount of the award, the trial court divided equally all of the marital property, including the Lotto winnings. The Court of Appeals held that the trial court had appropriately considered the lottery winnings as marital property. Id. at 505. The Court, nevertheless, held: While no hard and fast rule can be laid down, and while each case must depend upon its own circumstances to insure that equity be accomplished, generally in a case such as this the eighth factor should be given greater weight than the others. Where one party, wholly through his or her own efforts, and without any direct or indirect contribution by the other, acquired a specific item of marital property after the parties have separated and after the marital family has, as a practical matter, ceased to exist, a monetary award representing an equal division of that particular property would not ordinarily be consonant with the history and purpose of the statute. The trial judge found that the annuity was acquired because Mr. Alston "took the time and effort and money, whatever it cost, to purchase the lottery ticket." While the amount of effort itself may not have been great, the annuity was acquired entirely through Mr. Alston's efforts. This is not a case in which one party has facilitated the other's acquisition of property, directly or indirectly. Mr. Alston, using his own funds, purchased the ticket and won the Lotto. This event was not dependent in any way on the parties' joint efforts or shared life, past or present. At the time, the marriage was, for all practical purposes, over. Id. at 507-08. Judge Moylan, analyzed Alston as follows: A sweeping holding such as that urged by the appellant, moreover, would render meaningless the 98% of the Alston opinion that preceded it. The Court did not announce a rule of law that after-acquired gambling winnings are not marital property or are not subject to a monetary award. The Court in Alston carefully pointed out that the trial judge must weigh numerous relevant factors and then exercise "sound discretion." Even given facts such as those in Alston, the Court of Appeals listed and explained the criteria that should guide the exercise of discretion. It emphasized the special weight that should be given to the eighth factor. It analyzed cases from around the country, 331 Md. at 508-09, 629 A.2d 70, and stressed that in Maryland, unlike in many other states, "equitable" distribution is not necessarily "equal" distribution: In making a marital property monetary award, a trial judge must weigh the relevant factors in light of the legislative purpose, and then use his or her sound discretion to arrive at an award that is equitable and in accordance with the statute. Of course, equal distribution may often be proper, and where that result is equitable and consistent with the legislative purpose, a court should not hesitate to make such an award. Each divorce situation is different, and must be evaluated individually. In light of the peculiar circumstances of this case, however, the trial judge erred in awarding half of the Lotto annuity to Mrs. Alston. (331 Md. at 509, 629 A.2d 70.)