Addie vs. Coale

Addie vs. Coale has a history in the 4th district. When it was first appealed, it was remanded for reconsideration of the alimony and child support aspects of the final judgment. On remand, the successor trial judge entered an alimony and child support award, but it was deficient in that findings were not made on […]

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McGlynn vs. Tallman-McGlynn

In McGlynn vs. Tallman-McGlynn, we are reminded that if you include bonus income in your financial affidavit but want to argue that it should not be included in net income for alimony or child support, you should be prepared to present evidence supporting the claim that the bonus income is non-recurring. Also, the Former Husband […]

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Lathrop vs. Lathrop

In Lathrop vs. Lathrop, the trial court rightfully awarded alimony, but it erred in requiring that the alimony be secured by life insurance. In the absence of special circumstances, a spouse cannot be required to maintain life insurance for the purpose of securing an alimony obligation. A final judgment of dissolution must set forth sufficient […]

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Florida Alimony Bill Update

House Bill 455 is the current Alimony Bill under consideration. It passed the Civil Justice Subcommittee by a vote of 9-4, and then was passed to the Judiciary Committee. An amendment was added yesterday (not a substantive amendment). A vote will be upcoming in the Judiciary committee shortly (not yet scheduled), and if it passes […]

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Benedict v. Benedict

In Benedict vs. Benedict, the trial court entered a judgment for alimony arrearages while a petition seeking to downwardly modify alimony was pending. The appellate court affirmed the judgment, but noted that the debtor is able to proceed in the future to obtain relief from the judgment (under Rule 1.540(b)(5)) to the extent that the […]

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Taylor v. Taylor

Taylor v Taylor In Taylor v. Taylor, the 2d DCA reverses an award of durational, rather than permanent, alimony. The identified problem essentially was twofold, but really comes down to an absence of statutory findings. There is a lack of findings necessary to support the use of durational rather than permanent alimony, and the amount […]

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