(dissenting). I respectfully dissent and would affirm the trial court’s rulings regarding the property division and attorney fees.
i
The entire thrust of the majority opinion is that the trial court erred in the distribution of property in this divorce action because the distribution included portions of defendant’s separate estate either accumulated before the marriage or to which plaintiff made no contribution. Even conceding that the court invaded defendant’s separate estate, the separate assets of a party may be distributed where, as here, *499the marital assets are insufficient for the suitable support and maintenance of either party. MCL 552.23; MSA 25.103. In light of the trial court’s findings of fact, which were based on the evidence and the parties’ testimony, I find no error in the trial court’s property distribution.
The trial court considered the factors established in Sparks v Sparks, 440 Mich 141, 159-160; 485 NW2d 893 (1992), in determining an equitable division of property. Regarding the first factor, the length of the marriage, it held:
[E]quitably speaking here . . . the Court should look at the entire picture and not just the four years that they were married because, in all respects other than having legally tied the knot, the parties were operating as a marriage partnership. . . . [I]t’s equitable and appropriate to consider the period prior to the marriage that they were living together and acting as if they were married and conducting themselves in that manner .... So, I’m considering this, equitably speaking, as an eight-year marriage ....
This finding was not clearly erroneous given the evidence that the parties held themselves out as man and wife during the period of cohabitation, jointly buying rental property, opening joint bank accounts, and filing a joint income tax return in 1990, before their marriage. Heike v Heike, 198 Mich App 289, 291; 497 NW2d 220 (1993); Nielsen v Nielsen, 179 Mich App 698, 699-700; 446 NW2d 356 (1989).
With regard to the second factor, the trial court found the contributions of the parties to the marital estate to be equal. The court concluded:
[T]he total contribution, when you add it all up, amounts to equality.... [I]n this marriage, both parties contributed a great deal. And both parties actually contributed to the *500physical assets, although Mr. Reeves contributed more physical assets than Mrs. Reeves did; but she contributed in other ways that created an equality over the eight years.
The third and fourth factors are the age and health of the parties. Sparks, supra at 160. While the trial court did not find age to be a factor affecting property division, it concluded that plaintiff’s more precarious health required that additional assets be allocated to her.
The fifth factor, the life status of the parties, led the trial court to make findings that show plaintiff’s additional needs, contrary to the assertion of the majority opinion. The trial court opinion holds:
Mr. Reeves really took Mrs. Reeves out of a different style of life and brought him (sic) into a — brought her into his style of life, which was in a different category, in a different life station; and now, she can’t just be dropped back into her previous life station and needs to maintain a life station now that she has been used to for the last eight years or similar to that, it may not be exactly the same or it may never rise again to that level, but it is at a different level and needs to be taken into consideration .... She needs more of the assets in order to do that.
This is precisely the factor that the majority opinion notes is a justification for the invasion of a separate estate. MCL 552.23; MSA 25.103; Charlton v Charl-ton, 397 Mich 84, 94; 243 NW2d 261 (1976).
The trial court made only passing reference to the sixth factor, the necessities and circumstances of the parties, but discussed the seventh factor, the earning abilities of the parties, at length, concluding what is obvious from the record: defendant has a much greater ability to earn an income than does plaintiff. Strong emphasis was placed on this factor:
*501His earning ability is much broader and more extensive and far outweighs hers, and so that’s a heavy factor that is weighed by the Court toward compensating her, so that she can deal with her future and be a — appropriated [sic] maintained by her own earning ability in the future, when she’s not gonna [sic] have his earning ability to assist her, as she had over the past eight years.
The eighth factor, fault, was discounted by the court as a basis for the property division. When the court discussed the ninth factor, general principles of equity, it briefly referred for a second time to the fact that, before the parties’ cohabitation and marriage, plaintiff had a very modest lifestyle that was changed considerably by her relationship with defendant. The court discussed defendant’s many and varied business dealings, his business acumen, and his greater potential for long-term financial security. The court also opined that defendant had been less than candid in disclosing the extent of his assets and their value and farther stated its view that defendant had taken advantage of plaintiff’s lack of sophistication in some of his financial dealings involving her.
n
The record supports the trial court’s findings in every particular. Although our review is de novo, we review findings of fact for clear error, and where they are upheld, we determine whether the dispositional rulings were fair and equitable in light of those facts. Sparks, supra at 147, 151-152; Beason v Beason, 435 Mich 791, 805; 460 NW2d 207 (1990). Moreover, because dispositional rulings are discretionary, they should be affirmed unless we are left with the film conviction that the division is inequitable. Sparks, supra at 152; Kuntze v Kuntze, 351 Mich 144, 148; 88 *502NW2d 608 (1958); Whittaker v Whittaker, 343 Mich 267, 272; 72 NW2d 207 (1955). After reviewing the record and the arguments of the parties, I am left with no such conviction. Because I conclude that the property division was equitable under all the circumstances, I would affirm it.
in
I would likewise affirm the trial court’s denial of plaintiff’s request for attorney fees. We review this issue for an abuse of discretion. Hanaway v Hanaway, 208 Mich App 278, 298; 527 NW2d 792 (1995). Because the trial court did not find that an award was necessary to enable plaintiff to prosecute or defend this action, the denial of plaintiff’s request was not an abuse of discretion. Id. With regard to defendant’s lack of cooperation in disclosing the extent of his assets, the trial court considered this fact in determining the property division.