Alimony:
Parker v. Parker, 378 So.3d 681 (Fla. 2nd DCA 2024). Trial court reversed for basing alimony on gross income instead of net. Judge James S. Moody, III reversed.
Attorney’s Fees:
Morales v. Morales¸ 388 So.3d 901 (Fla. 3rd DCA 2024). Trial court affirmed for granting charging lien in amount greater than Court awarded from other party. Judge David Young affirmed.
Income:
Lemoine v. Jackson, 379 So.3d 540 (Fla 5th DCA 2023). Trial court erred imputing 160k in annual income where there was no evidence presented of the available employment that this party qualified for. Judge Michael J. Rudisill affirmed in part, reversed in part.
Injunctions:
Budlove v. Johnson, 377 So.3d 206 (Fla. 2nd DCA 2023). Stalking injunction reversed to the extent it was overbroad, and enjoined respondent from engaging in constitutionally protected speech. Judge Lauralee Ganson Westine affirmed in part, reversed in part.
Paylan v. Statton, 376 So.3d 822 (Fla. 2nd DCA 2023). Trial court affirmed for dismissing stalking injunction based on 6 emails from a year and a half ago, and respondent removing a lawn turtle from petitioner’s property. Course of conduct was lacking to support injunction. Judge Doneene D. Loar affirmed.
Kollmann v. Caudill, 377 So.3d 184 (Fla. 2nd DCA 2023). DV injunction involving animal trainer and circus performer. Injunctions affirmed except for classifying a kangaroo, 3 zebras and 4 camels as family pets, which they were not. Judge Monique M. Scott affirmed in part, reversed in part.
Modification:
Cipollina v. Cipollina, 380 So.3d 498 (Fla. 2nd DCA 2024). Trial court erred granting upward modification of alimony when former husband opened new franchise and was operating at a loss. Judge Maria Ruhl reversed.
Procedure:
Gerber v. Dubrowski, 376 So.3d 812 (Fla. 2nd DCA 2023). Trial court abused discretion denying motion for leave to amend request for relocation. Request was made 48 days before trial and presented no significant changes or new allegations. Judge Wesley D. Tibbals affirmed in part, reversed in part.
Hopf v. Kaszuba, 376 So.3d 105 (Fla. 2nd DCA 2023). Former Wife sought certiorari review of order denying request to discharge guardian ad litem. GAL did not provide the required notice of who she was interviewing. However, Wife could not establish irreparable harm. Writ dismissed.
Support:
Hardwick v. Smith, 49 Fla.L.Weekly D36 (Fla. 1st DCA 2023). Father was entitled to retroactive support prior to date of filing petition because child came to live with Father. Judge Dawn Caloca-Johnson reversed.
Relocation:
Ward v. Waters, 389 So.3d 652 (Fla. 3rd DCA 2024). Final judgment denying relocation and granting long-distance parenting plan without explanation reversed. The disconnect between the two concurrent rulings is impossible to reconcile without further explanation from the trial court. Judge Bonnie J. Helms affirmed in part, reversed in part.
Alimony:
Parker v. Parker, 378 So.3d 681 (Fla. 2nd DCA 2024). Trial court reversed for basing alimony on gross income instead of net. Judge James S. Moody, III reversed.
Attorney’s Fees:
Morales v. Morales¸ 388 So.3d 901 (Fla. 3rd DCA 2024). Trial court affirmed for granting charging lien in amount greater than Court awarded from other party. Judge David Young affirmed.
Income:
Lemoine v. Jackson, 379 So.3d 540 (Fla 5th DCA 2023). Trial court erred imputing 160k in annual income where there was no evidence presented of the available employment that this party qualified for. Judge Michael J. Rudisill affirmed in part, reversed in part.
Injunctions:
Budlove v. Johnson, 377 So.3d 206 (Fla. 2nd DCA 2023). Stalking injunction reversed to the extent it was overbroad, and enjoined respondent from engaging in constitutionally protected speech. Judge Lauralee Ganson Westine affirmed in part, reversed in part.
Paylan v. Statton, 376 So.3d 822 (Fla. 2nd DCA 2023). Trial court affirmed for dismissing stalking injunction based on 6 emails from a year and a half ago, and respondent removing a lawn turtle from petitioner’s property. Course of conduct was lacking to support injunction. Judge Doneene D. Loar affirmed.
Kollmann v. Caudill, 377 So.3d 184 (Fla. 2nd DCA 2023). DV injunction involving animal trainer and circus performer. Injunctions affirmed except for classifying a kangaroo, 3 zebras and 4 camels as family pets, which they were not. Judge Monique M. Scott affirmed in part, reversed in part.
Modification:
Cipollina v. Cipollina, 380 So.3d 498 (Fla. 2nd DCA 2024). Trial court erred granting upward modification of alimony when former husband opened new franchise and was operating at a loss. Judge Maria Ruhl reversed.
Procedure:
Gerber v. Dubrowski, 376 So.3d 812 (Fla. 2nd DCA 2023). Trial court abused discretion denying motion for leave to amend request for relocation. Request was made 48 days before trial and presented no significant changes or new allegations. Judge Wesley D. Tibbals affirmed in part, reversed in part.
Hopf v. Kaszuba, 376 So.3d 105 (Fla. 2nd DCA 2023). Former Wife sought certiorari review of order denying request to discharge guardian ad litem. GAL did not provide the required notice of who she was interviewing. However, Wife could not establish irreparable harm. Writ dismissed.
Support:
Hardwick v. Smith, 376 So.3d 806 (Fla. 1st DCA 2023). Father was entitled to retroactive support prior to date of filing petition because child came to live with Father. Judge Dawn Caloca-Johnson reversed.
Relocation:
Ward v. Waters, 389 So.3d 652 (Fla. 3rd DCA 2024). Final judgment denying relocation and granting long-distance parenting plan without explanation reversed. The disconnect between the two concurrent rulings is impossible to reconcile without further explanation from the trial court. Judge Bonnie J. Helms affirmed in part, reversed in part.
Stephens & Stevens Marital & Family Law 
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