In re the Marriage of: Ellen Doneen and James Doneen

Lawrence-Berrey, A.C.J.

¶ 1 Ellen Doneen appeals the trial court’s property distribution in the dissolution of her 45-year marriage to James Doneen. She primarily argues the trial court erred as a matter of law when it failed to distribute all property, regardless of its character, roughly equally. We take this opportunity to clarify the law: in reaching a just and equitable distribution of property under RCW 26.09.080, trial courts must consider multiple factors, including four statutory factors. Although the duration of the marriage or domestic partnership is one statutory factor, this…