Arquette v. Rutter

The followingis a child support modification case under UIFSA. The Florida court never obtained subject matter jurisdiction allowing it to modify the foreign court’s child support order, so the modification was void. UIFSA has specific requirements to grant a state the jurisdiction to modify a foreign court’s child support order, none of which was satisfied […]

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Ellisen v. Ellisen

The trial court in the attached case misconstrued the pleadings, and denied a petition for modification of alimony based upon the wrong legal standard. When modification of an existing order of support is sought, the proof required to modify a settlement agreement and the proof required to modify an award established by court order shall […]

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Wood v. Blunck

The following is an alimony modification case. The substantial change of circumstances necessary to modify an alimony award must bear on either the payee spouse’s need for alimony or the payor spouse’s ability to pay it. When the payee spouse’s need decreases significantly, alimony should ordinarily be modified downward even if the payor spouse has […]

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Gerber v. Gerber

In the following case, the Former Husband was held in contempt of an order regarding the repayment of medical expenses. However, the contempt finding was premature in that the finding of contempt occurred in the same hearing as a clarification of the order at issue. An order that is indefinite or ambiguous may not be […]

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