Stephens & Stevens Marital & Family Law

Stephens Squibs – 2025 ANNUAL

Written by: 

Eddie Stephens, Esquire

Edited by: 

Caryn A. Stevens, Esquire

 Associate Editors:

Sarai Q. Glaze and Noelle E. Stone

Eddie Stephens | Author

Eddie Stephens, a sixth-generation Floridian, is a partner at Stephens & Stevens, PLLC and a Board Certified Marital & Family Law attorney who concentrates on high-conflict, high-asset divorce litigation. He holds the AV® Preeminent™ Peer Review Rating from Martindale-Hubbell and brings more than 25 years of courtroom experience to complex matters involving equitable distribution, business valuation, support, parenting disputes, relocation, post-judgment litigation, same-sex family issues, and premarital/postmarital agreements. Eddie is widely recognized for integrating trauma-informed practices into his advocacy, helping clients navigate litigation with clarity and steadiness. He serves on the Board of Directors for the Center for Child Counseling, Inc. His honors include the Family Law Section Alberto Romero Making a Difference Award (2017), Leadership Excellence Award (2018), and Harriet Goldstein Award (2019).

Caryn A. Stevens | Editor

Caryn A. Stevens is a Partner at Stephens & Stevens, PLLC in West Palm Beach, practicing exclusively in marital and family law. Before becoming an attorney, Caryn spent more than 12 years in mental health and counseling, including private practice, the Department of Children & Families, and as an elementary school guidance counselor. She earned her B.S. in Psychology and her M.S./Specialist Degrees in Counseling & Human Services from Florida State University, and her J.D. from Nova Southeastern University, where she received pro bono honors. Caryn’s counseling background informs her compassionate, client-centered advocacy and strong courtroom presence. In 2021, she received the Florida Bar Family Law Section’s Alberto Romero Making a Difference Award for outstanding pro bono service and community impact. A Leadership Palm Beach County Class of 2019 graduate, Caryn serves as Co-Chair of Leadership GROW and mentors through Women of Tomorrow. She lives in Palm Beach County with her husband, David, and Mini Aussie, Emma.

Sarai Glaze | Associate Editor

Sarai Glaze is an Associate Attorney at Stephens & Stevens, PLLC, bringing a compassionate, client-focused approach to family law advocacy. Prior to joining the firm, she represented veterans exposed to asbestos as a plaintiff’s attorney, helping clients pursue accountability and compensation while navigating high-stakes litigation. That work strengthened her ability to guide people through complex legal challenges with empathy and resolve. Sarai earned her Juris Doctor from Florida State University College of Law. She graduated magna cum laude from The Ohio State University with a bachelor’s degree in history and a certificate in leadership. Originally from Long Island, New York, Sarai now calls Florida home and enjoys hiking, concerts, volunteering, and spending time with family and friends.

Noelle Stone | Associate Editor

Noelle Stone is a Florida native and a licensed attorney in New York and New Jersey. She joined Stephens & Stevens, PLLC as a law clerk while awaiting admission to the Florida Bar. Noelle earned her bachelor’s degree in legal studies from Florida Gulf Coast University and was selected as a Newman Civic Fellow for her commitment to civic engagement. She received her Juris Doctor from Brooklyn Law School, where she was a member of the Alternative Dispute Resolution Honor Society and was inducted into the Order of the Barristers for excellence in oral advocacy, trial skills, and legal writing. After law school, Noelle served as a law clerk to the Honorable Patrick J. Bartels in the Family Division of the Mercer County, New Jersey Superior Court. Outside of work, she enjoys beach days with family, surfing, and knitting, and is happy to be back in the Sunshine State.

Agreements:

Third DCA:

Duran v. Duran, 403 So.3d 1039 (Fla. 3^rd DCA 2025).  Order declining to enforce prenuptial agreement affirmed when supported by competent evidence.  Judge Oscar Rodriguez Fonts affirmed.

Fifth DCA:

Martin v. Sater, 50 Fla.L.Weekly D2636 (Fla. 5^th DCA 2025). Affirms trial court for applying 12.540 instead of Casto analysis to set aside MSA on motion filed after entering final judgment. Court recedes from Suppa, 871 So.2d 988 and certifies question whether Macar, 803 So.2d 707, requires 12.540 or Casto on issues to set aside MSA when motion filed after final judgment has been entered.  Judge Kathryn M. Speicher affirmed.

Sixth DCA:

Rushing v. Rushing, 50 Fla.L.Weekly D2091 (Fla. 6^th DCA 2025). Trial court erred by misconstruing formula in MSA on how to calculate Wife’s share of military retirement. Judge Mikaela Nix-Walker reversed.

Alimony:

First DCA:

Zargari v. Zargari, 416 So.3d 1172 (Fla. 1^st DCA 2025). Trial court erred awarding $6,000/month in alimony without considering wife’s ability to work part-time, or her potential income earned from a commercial property. Judge John Jay Gontarek affirmed in part, reversed in part.

Bales v. Bales, 409 So.3d 1284 (Fla. 1^st DCA 2025). Award of permanent alimony reversed as case was still pending as of July 1, 2023 (when alimony law changed), because motion for rehearing had not been disposed of yet. Judge T. Michael Jones reversed.

Stockdale v. Stockdale, 409 So.3d 163 (Fla 1st DCA 2025). Award of permanent alimony was in error for case heard in May 2023 and judgment issued in August 2023 was pending as of July 1, 2023 when permanent alimony was abolished. Judge Darlene F. Dickey reversed.

Second DCA:

Woodward v. Woodward, 400 So. 3d 861 (Fla. 2^nd DCA 2025).  Trial court entered final judgment in February 2023.  Permanent alimony was eliminated by legislation for any case initiated or pending as of July 1, 2023.   Because this case was appealed, the matter was still pending as of July 1, 2023, so permanent alimony is not an option even though final judgment originally entered in February 2023. On remand, court needs to consider ability, adultery and whether a supportive relationship exists. Judge Lindsey M. Alvarez affirmed in part, reversed in part.

Fourth DCA:

Beck v. Tamas-Beck, 50 Fla.L.Weekly D2492 (Fla. 4th DCA 2025). Trial court erred requiring life insurance for support without findings of availability, affordability and special circumstances. Trial court also miscalculated duration of marriage. Judge Michael Davis affirmed in part, reversed in part.

Wallace v. Wallace, 418 So.3d 148 (Fla. 4^th DCA 2025).  Trial court erred awarding alimony when record contained no evidence of need. Judge Karen M. Miller affirmed in part, reversed in part.

Loconto v. Loconto, 415 So.3d 696 (Fla. 4^th DCA 2025). Trial court erred awarding only $500 a month in durational alimony when Husband had an ability to pay $949 a month, and Wife has a need as she is blind and Husband always supported her during 50-year marriage. Judge Lauren Alperstein affirmed in part, reversed in part.

Alfonso v. Gordon Alfonso, 50 Fla.L.Weekly D1043 (Fla. 4^th DCA 2025). Legislation eliminated permanent alimony for all future and pending cases as of July 1, 2023.  Trial court entered final judgment awarding permanent alimony on June 30, 2023.  Husband filed motion for rehearing on July 1, 2023.  Trial courts have addressed rendering final judgment in different ways in different contexts. Majority in fourth district concludes it is upon entry of final judgment.   Strong dissent that argues not final until rehearings are disposed of (editor’s note, this is better argument!).   This case conflicts with others, but conflict not certified.  Leatha D. Mullins affirmed in part, reversed in part.

Edman v. Edman, 407 So.3d 452 (Fla. 4th DCA 2025). Even without transcript, final judgment that does not contain findings of wife’s need and husband’s ability to pay, reversed. Judges Karen M. Miller and John Lenderman affirmed in part, reversed in part.

Smith v. Chevillet, 403 So.3d 230 (Fla. 4^th DCA 2025).  Trial court erred awarding rehabilitative alimony when record had no evidence to support award.  Discussion between attorney for one party and judge about a potential stipulation was not an agreement without the unequivocal assent of the other party.  Fact court failed to make required findings was waived by party’s failure to seek rehearing. Judge Darren Shull reversed.

Fifth DCA:

Secrist v. Secrist, 50 Fla.L.Weekly D2105 (Fla. 5^th DCA 2025). Trial court erred by failing to apply new alimony statute to a case that was tried and Court made oral pronouncement on June 30, 2023. but the matter was still pending when the law changed on July 1, 2023 as no final judgment has been entered. Judge Gary L. Wilkinson affirmed in part, reversed in part.

Woodlief v. Woodlief, 415 So.3d 1208 (Fla. 5^th DCA 2025). Trial court denied wife’s request for permanent alimony because she had no need, but granted her 5 years of durational alimony at $500/month because “she was very anxious about her future.” Matter remanded because Court failed to make a finding of actual need. Judge Suzanne Bass affirmed in part, reversed in part.

Eberhart v. Eberhart, 415 So.3d 229 (Fla. 5th DCA 2025). Even without transcript, it was clear from face of judgment that trial court erred calculating alimony and child support based on parties’ gross incomes. Judge Jigisa Bhikhubhai Dookhoo affirmed in part, reversed in part.

Frazier v. Dodd, 406 So.3d 1034 (Fla. 5th DCA 2025). Trial court erred granting alimony without any findings of wife’s expenses. Judge Brian J. Welke reversed.

Sixth DCA:

Shouman v. Salama, 404 So.3d 616 (Fla. 6th DCA 2025). Trial court erred first finding wife has need of $4000/month, then concluding wife did not prove need based on being able-bodied, capable of working and receiving large equitable distribution. Trial court also erred including expenses the husband did not actually pay in determining his ability. Judge Michael Deen reversed.

Annulment:

Third DCA:

Rojas v. Londono, 404 So.3d 579 (Fla. 3^rd DCA 2025).  Trial court affirmed for denying annulment when record demonstrated marriage was consummated and wife did not enter marriage fraudulently.  Judge Christina Marie DiRaimondo affirmed.

Appeals:

First DCA:

Nisewonger v. Nisewonger, 416 So.3d 1262 (Fla. 1^st DCA 2025). Appellate court did not have jurisdiction to review order denying motion to set aside, as appellant appealed the wrong order. Judge Darlene Fallon Dickey affirmed.

Zargari v. Zargari, 416 So.3d 1172 (Fla. 1^st DCA 2025). Wife raised over a dozen issues without full elaboration or legal support. Appealing party must “make error clearly appear,” and this duty is not discharged by posing a question with accompanying assertion that it was improperly answered by trial court, then dumping the matter in the lap of the appellate court for decision. High threshold for finding abuse of discretion restated. Judge John Jay Gontarek affirmed in part, reversed in part.

Second DCA:

Taylor v. Carlson, 407 So.3d 1263 (Fla. 2d DCA 2025). Motion for rehearing of order, entered after hearing before magistrate, did not toll the time after a motion to vacate had already been ruled upon.  Appeal dismissed.

Third DCA:

Miller v. Ko, 50 Fla.L.Weekly D2532 (Fla. 3^rd DCA 2025). Fact appellant did not include in notice of appeal that there was a motion for rehearing pending as required did not waive abeyance until circuit court ruled on motion. Judge Spencer Multack affirmed.

Lysich v. Canelo f/k/a Lysich, 50 Fla.L.Weekly D2463 (Fla. 3rd DCA 2025). Order correcting child support but reserving on arrears is a non-final order, not subject to appeal. Appeal dismissed.

Khare v. Khare, 50 Fla.L.Weekly D2356 (Fla. 3rd DCA 2025). Appellate court could not determine if trial court erred dismissing divorce for lack of personal jurisdiction, subject matter jurisdiction and forum non-conveniens without transcript. Judge Spencer Multack affirmed.

Olivas v. Morales, 420 So.3d 1091 (Fla. 3^rd DCA 2025). Appellate court cannot determine if judge misconstrued evidence on summer timesharing without a transcript. Judge Gina Beovides affirmed.

Naranjo v. DOR, 419 So.3d 774 (Fla. 3^rd DCA 2025). Administrative order must be affirmed when no transcript presented and there is no error on the face of the order.

Hewell v. Hewell, 418 So.2d 844 (Fla. 3^rd DCA 2025). Appellate Court cannot review Husband’s complained errors on equitable distribution, as no transcript was provided. Judge Spencer Multack affirmed.

Lopez v. Fernandez, 415 So.3d 349 (Fla. 3^rd DCA 2025). Final judgment of injunction affirmed when there is no transcript provided, and no error on the face of the judgment. Judge Stacy D. Glick affirmed.

Song v. Luo, 415 So.3d 338 (Fla. 3^rd DCA 2025). Appellate court summarily affirmed order after service of initial brief, as record provided appellant had immediate right of possession. Judge Christina Marie DiRaimondo affirmed.

Saenz v. Diaz, 416 So.3d 352 (Fla. 3^rd DCA 2025). Order granting modification affirmed when no transcript provided, and there was no error on the face of the judgment. Judge Marlene Fernandez-Karavetsos affirmed.

Nikolaev v. Nikolaeva, 411 So.3d 525 (Fla 3d DCA 2025). Appellant could not challenge final judgment without record. Judge Jason Emilios Dimitris affirmed.

Shaw v. Perez-Shaw, 418 So.3d 308 (Fla 3d DCA 2025). Trial court affirmed for granting emergency motion for supervised timesharing when appellant failed to provide a record. Judge Veronica Diaz affirmed.

Magana v. Machado, 406 So.3d 317 (Fla. 3^rd DCA 2025).  Former husband failed to provide transcript to appellate court, and also failed to seek rehearing on failure to make findings in final judgment. Judge Christina Marie DiRaimondo affirmed.

Fourth DCA:

Weinstein v. Weinstein, 50 Fla.L.Weekly D2344 (Fla. 4th DCA 2025). A finding of entitlement to attorney’s fees without determination of amount is a non-final, non-appealable order. Judge Laura Burkhart affirmed in part, reversed in part.

Marcellus v. Peterson, 419 So.3d 1094 (Fla. 4^th DCA 2025). Trial court erred by exceeding mandate. Judge Natasha DePrimo affirmed in part, reversed in part.

Goya v. Hayashida, 418 So.3d 652 (Fla. 4^th DCA 2025). Pro se appellee scolded for using hallucinated cases generated by AI. An attempt to persuade a Court or oppose an adversary by relying on fake opinions is an abuse of the legal system. Judge Fabienne E. Fahnestock affirmed in part, reversed in part.

Fifth DCA:

McPherson v. Samuel, 392 So.3d 565 (Fla. 4^th DCA 2025). Trial court affirmed for granting costs to appellant who won the right to a new D.V. hearing due to due process violation, but ultimately did not obtain injunction. Conflict certified with Varveris v. Charbonell, 785 So.2d 576 (Fla. 3^rd DCA 2011).  Judge Kevin P. Tynan affirmed. 

Stivelman v. Stivelman, 386 So.3d 975 (Fla. 5th DCA 2025). Appellate court vacated order issued before mandate because trial court did not have jurisdiction. Judge Ivonne Cuesta’s order vacated.

Attorney’s Fees:

First DCA:

Second DCA:

Third DCA:

Schultheis v. Schultheis, 50 Fla.L.Weekly D2345 (Fla. 3rd DCA 2025). A finding of entitlement to attorney’s fees without determination of amount of fees is not appealable. Judge Spencer Multack affirmed in part, reversed in part.

Breton v. Raud, 50 Fla.L.Weekly D2064 (Fla. 3rd DCA 2025).Error to award Mother $100k in temporary and prospective attorney’s fees, and $55k in temporary and prospective accounting costs, when motion requested $35k in fees and $5k in accounting costs. Judge Victoria Del Pino affirmed in part, reversed in part.

Gutierrez v. Gutierrez, 418 So.3d 306 (Fla. 3^rd DCA 2025). Trial court affirmed for denying motion for attorney’s fees. Judge’s comment that former husband has ability to teach during summer was not an improper imputation.  Gratuitous judicial observations having no bearing on an outcome of dispute are “obiter dictum.” Judge Marlene Fernandez-Karvetsos affirmed.

Abbey v. Abbey, 50 Fla.L.Weekly D2151 (Fla. 3^rd DCA 2025). Appeal seeking review of a finding of entitlement to fees without amount is dismissed as premature. Order is not final until amount is set. Judge Sharon I. Hamilton affirmed in part, appeal dismissed in part.

Gonzalez v. Rodriguez, 418 So.3d 245 (Fla. 3^rd DCA 2025). Trial court abused discretion awarding $75,000 in temporary attorney’s fees based on determination that Husband can obtain funds “without limitation” and “on demand” from his friends and family. When determining ability, Court can only consider party’s ability unless they are receiving continuing, non-sporadic gifts.   Judge Abby Cynamon reversed. 

Perez-Palma v. Rodriguez, 413 So.3d 866 (Fla. 3^rd DCA 2025). 3^rd DCA sides with 6^th DCA, and concludes F.S. 742.045 does not authorize attorney’s fees in paternity appeals, and certifies conflict with 4^th and 5^th DCAs. Judge Scott M. Bernstein affirmed in part, reversed in part.

Fourth DCA:

Marcellus v. Peterson, 419 So.3d 1094 (Fla. 4^th DCA 2025). Entitlement to vexatious attorney’s fees affirmed, but amount of $282,000 remanded as not supported with findings of rates and duration. Judge Natasha DePrimo affirmed in part, reversed in part.

Cohen v. Cohen, 414 So.3d 244 (Fla. 4^th DCA 2025). Trial court erred denying prevailing party his attorney fees for failing to present corroborating expert testimony that his fees are reasonable. F.S. 61.16 specifically includes exception to requirement of corroborating testimony in prevailing party.  Differentiates Roshkind v. Machiela, which involved an attorney seeking fees against client, as opposed to two parties in a family law proceeding. Judge Rosemarie Scher reversed.

Graydus v. Graydus, 414 So.3d 213 (Fla. 4^th DCA 2025). Trial court erred awarding attorney’s fees where there was no evidence or testimony regarding requesting party’s financial needs.  It is not enough just to show other side’s ability to pay. Judge Sherwood Bauer affirmed in part, reversed in part.

Nicholas v. Nicholas, 495 So.3d 363 (Fla. 4th DCA 2025). Trial court erred adding a provision to parties’ agreement that remaining fees will be paid from marital property when relief not requested and all marital assets had already been distributed. Judge Elaine A. Carbuccia affirmed in part, reversed in part.

Fifth DCA:

Mickler v. Iizuka, 415 So.3d 1175 (Fla. 5^th DCA 2025). Trial court erred denying a 57.105 motion based on a party pursuing a tort claim that had been previously released.  Judge Waddell Arlie Wallace, III reversed.

Kiswani v. Hafza, 403 So.3d 416 (Fla. 5^th DCA 2025).  Trial court erred awarding attorney’s fees without assessing the parties’ need and ability to pay.  Judge Michael J. Rudisill affirmed in part, reversed in part.

Discovery:

Third DCA:

Kraushaar v. Kraushaar, 50 Fla.L.Weekly D2363 (Fla. 3rd DCA 2025). Writ of certiorari granted on discovery order that sought any and all medical records from 2011 was too broad of a net on an issue of who gets the emotional support dog in equitable distribution, when there was an allegation the support dog might be a fraud. Judge Marcia Del Rey’s order quashed.

Delgado v. Miller, 50 Fla.L.Weekly D2150 (Fla. 3^rd DCA 2025). Party sought writ of certiorari to prevent follow-up deposition without cause in a contentious paternity matter. However, there would be no irreparable harm, and court did not depart from essential requirements of law. Writ of Certiorari concerning Judge Spencer Multack’s order dismissed.

Oramas v. Asencio, 415 So.3d 302 (Fla. 3^rd DCA 2025). Discovery order allowing discovery of non-party’s finances quashed when neither record nor pleadings established relevancy. Judge Samantha Ruiz Cohen’s order quashed.

Fifth DCA:

DOR o/b/o Brown v. Gardner, 416So.3d 1167 (Fla. 5^th DCA 2025). Trial court erred ordering scientific testing, when Father signed voluntary acknowledgement of paternity which was not rescinded within 60 days. After 60 days, paternity can only be challenged on basis of fraud, duress or material mistake of fact. Judge Sandra C. Upchurch’s order quashed.

Disestablishment of Paternity:

Fifth DCA:

Martinez v. Cuevas, 416 So.3d 371 (Fla. 5^th DCA 2025).  Trial court erred denying request to disestablish paternity of children born during marriage, when children were born after husband’s vasectomy, as the Husband should have known children were not his. Wife assured Husband it was his child provided basis for scientific testing. Discussion over split in districts over whether scientific testing constitutes newly-discovered evidence. Judge Sylvia A. Grunor reversed.

Enforcement:

Second DCA:

Marin v. Marin, 50 Fla.L.Weekly D2229 (Fla. 2^nd DCA 2025). Trial court erred granting $700k money judgment as sanction for party failing to maintain life insurance with death benefit in the amount of $700k, as this is not a valid contempt sanction.  Judge Maria Ruhl reversed in part, affirmed in part.

Said v. Bell, 407 So.3d 1273 (Fla. 2d DCA 2025). Trial court erred holding party in contempt for failure to make equalizing payment. Judge Brian Edward Gnage affirmed in part, reversed in part.

Third DCA:

Garcia Azzam v. Diaz De La Portilla, 420 So.3d 658 (Fla. 3^rd DCA 2025). Writ of certiorari directed at order granting contempt, where party did not receive proper notice, quashed.  Judge Ivonne Cuesta’s   quashed.

Maradona v. Villafane, 420 So.3d 1077 (Fla. 3^rd DCA 2025). Order that looks like criminal contempt reversed when party not afforded required due process safeguards, nor did the order contain a proper purge provision. Judges Carlos Lopez and Spencer Eig affirmed in part, reversed in part.

Prichard v. Galicia, 407 So.3d 537 (Fla 3d DCA 2025). Writ of certiorari granted to quash $1,000 day coercive fine as it was not based on the party’s ability to pay. Judge Abby Cynamon, order quashed.

Phanord v. Phanord, 411 So.3d 568 (Fla. 3^rd DCA 2025). Former wife sought contempt for unpaid support 30 years after final judgment. Trial court erred concluding former husband waived latches defense by not pleading it as an affirmative defense. Affirmative responses are only required when responding to a pleading. A motion for contempt is not a pleading per Rule 12.615(b). Judge Marina Del Rey reversed.

Bouquet v. Jones, 408 So.3d 869 (Fla. 3d DCA 2025). Order finding husband in contempt affirmed when husband thwarted discovery and was not credible. See Baratta v. Costa-Martinez, 139 So 3d 407 (Fla. 3d DCA 2014). Judge Jason Emilios Dimitris affirmed.

Fourth DCA:

Caron v. Caron, 50 Fla.L.Weekly D2492 (Fla. 4^th DCA 2025). Court erred in entering an ex parte order prohibiting the Wife from removing, selling or disposing of property in the parties’ former residence and ordering her to cancel an estate sale she had scheduled. Wife moved to dismiss such order and was denied. The order entered was a temporary injunction against Wife, even if not titled as such, because it granted injunctive relief and there was not sufficient findings to support the entry of an injunction.  Judge Lillian B. Ewen, reversed.

Bergman v. Bergman, 419 So.3d 85 (Fla. 4^th DCA 2025). Trial court erred denying prevailing party fees when no objection was made that it was not requested in pleadings. Trial court also erred by failing to award interest when it was clearly provided for in agreement. Judge Darren Shull reversed.

Flaim v. Flaim, 417 So.3d 1 (Fla. 4^th DCA 2025).  Trial court reversed for failing to equally distribute an escrow refund check on property that parties had agreed to equally divide proceeds on. Judge Darren Shull reversed.

Robilotta v. Karkhoff, 408 So.3d 23 (Fla. 4th DCA 2025). Trial court erred in awarding $100 for prosecution costs after indirect criminal contempt proceeding when prosecuted by private attorney. Trial court was without jurisdiction to award fees to private attorney for indirect criminal contempt, but appellant never filed a notice of appeal on that issue so appellate court could not address. Judge Laura C. Burkhart affirmed in part, reversed in part.

Healy v. Healy, 409 So.3d 128 (Fla. 4^th DCA 2025). Trial court erred vacating magistrate’s order denying motion for contempt, when school designation provided child goes to highest ranking school if parent lives in St. Lucie county.  Father was in car crash with children while intoxicated. Mother was granted sole parental responsibility, and restricted Father’s timesharing on emergency motion.  Mother moved to another county less than 50 miles away, and enrolled child in school.  Trial court erred holding Mother in contempt, as school designation was ambiguous and Mom had temporary sole decision-making authority which overrides the school designation provision. Judge Leatha D. Mullins reversed.

Fifth DCA:

Bazinet v. Pinkerton, 50 Fla.L.Weekly D2685 (Fla. 5^th DCA 2025). Order on contempt that changed school designation and modified timesharing reversed, as relief not plead for, and modification burden not met. Judge Michael G. Takac affirmed in part, reversed in part.

Kelly v. Kelly, 414 So.3d 474 (Fla. 5^th DCA 2025). Portion of contempt requiring incarceration if purge not met, reversed when there are findings that party had ability to meet the purge. Judge R. Gregg Jerald affirmed in part, reversed in part.

Lett v. Lett, 408 So.3d 167 (Fla. 5th DCA 2025). Court affirmed for awarding fees as a sanction per Fla. Stat. 61.13(4)(c)(2) without considering need, when mother found in contempt for missed timesharing, but $25 per day fine reversed when not requested in pleadings. Judge Jigisa Patel-Dookhoo affirmed in part, reversed in part.

Sixth DCA:

Saladino v. Saladino, 415 So.3d 270 (Fla. 6^th DCA 2025). Trial court violated former husband’s due process by awarding former wife sole parental responsibility and 100% timesharing at a hearing the former husband failed to attend when relief was not plead. Judge Russell T. Kirshy reversed.

Zinnurov v. Shelegina, 413 So.3d 975 (Fla. 6^th DCA 2025). Trial court erred granting an unsworn motion for contempt without a hearing or providing other party opportunity to respond. Judge Diana M. Tennis reversed.

Equitable Distribution:

First DCA:

Groom v. Groom, 50 Fla.L.Weekly D2293 (Fla. 1^st DCA 2025). On confession of error, trial court reversed for erroneous duplication of credit card balances.  All other issues affirmed. Judge John L. Miller, Jr. affirmed in part, reversed in part.

Second DCA:

Rose v. Rose, 50 Fla.L.Weekly D2402 (Fla. 2nd DCA 2025). The fact that Husband paid personal marital expenses from his pre-marital business was not sufficient to convert it to a marital property. Trial court erred charging a $30k depleted account when there was uncontroverted evidence it was spent on marital expenses. Judge Thomas M. Ramsberger affirmed in part, reversed in part.

Wilson v. Hurter, 50 Fla.L.Weekly D2117 (Fla. 2^nd DCA 2025). Trial court erred in methodology and calculating marital improvements on non-marital property.   Trial court must determine value added by enhancements, and divide by 2 as party owns property with a third-party. Judge William A. Burgess, III affirmed in part, reversed in part.

Cancel v. Cancel, 399 So.3d 371 (Fla. 2^nd DCA 2024).  Trial court erred failing to distribute marital portion of husband’s retirement that was not yet in pay status, because of no evidence of the value.  Court could have used “deferred distribution” method by assuming amount of benefit if husband had retired at time of trial without early retirement penalty, and multiplying it by percentage other spouse is entitled to.  Judge Brian Gnage affirmed in part, reversed in part.

Third DCA:

Noss v. Noss, 50 Fla.L.Weekly D2299 (Fla. 3^rd DCA 2025). Trial court erred distributing shares of third-party corporation that was not a party to lawsuit. Court had no evidentiary support for $15k cash assigned to wife. Judge Marcia Del Rey affirmed in part, reversed in part.

Levinas v. Levinas, 410 So.3d 124 (Fla. 3^rd DCA 2025). Parties agreed the Husband would refinance house and if not, the house would be sold. Husband was unable to refinance, so house was sold.  Husband was entitled to set-offs off set by his reasonable cost of occupancy.  Judge Victoria Del Pino reversed.

Pitamber v. Shivbaran, 414 So.3d 279 (Fla. 3^rd DCA 2025). Trial court erred denying equitable distribution of the marital house, as that was an impermissible sanction for the Wife challenging the validity of a prenuptial agreement to no avail. Judge Spencer Multack affirmed in part, reversed in part.

Busto v. Arias, 406 So.3d 1019 (Fla. 3d DCA 2025). Trial court’s business valuation affirmed in setting value of marital business without any expert testimony for goodwill affirmed, even though husband argued the court erred by including his salary as both an expense and an asset. Trial court also affirmed for valuing residence based on the wife’s financial affidavit when there was no other evidence of current value. Judge Spencer Multack affirmed.

Alvarez v. Stochetti, 406 So.3d 1007 (Fla 3d DCA 2025). Trial court affirmed for treating remaining debt of promissory note signed at commencement of husband’s employment with Morgan Stanley that is partially forgiven after each year of work as a contingent liability. Judge David Young, affirmed in part, reversed in part.

Michener v. Michener, 403 So.3d 1040 (Fla. 3^rd DCA 2025).  Trial court erred unequally distributing parties’ retirement accounts by over $250,000, because wife destroyed husband’s Star Wars collection (and other memorabilia) that he listed on his financial affidavit was worth $14,500, but he testified that certain items were priceless because they could not be replaced.  A sentimental interest of property by one party cannot takeover financial fairness to other party.  Judge Spencer Multack affirmed in part and reversed in part.

Fourth DCA:

Goya v. Hayashida, 418 So.3d 652 (Fla. 4^th DCA 2025). Trial court erred categorizing property as marital when there was no record evidence the Husband owned it. Judge Fabienne E. Fahnestock affirmed in part, reversed in part.   

Wallace v. Wallace, 418 So.3d 148 (Fla. 4^th DCA 2025).  Trial court erred including wife’s post-filing contributions to retirement in equitable distribution, and failed to consider husband’s retirement at all. Judge Karen M. Miller affirmed in part, reversed in part.

Reed v. Reed, 403 So.3d 857 (Fla. 4^th DCA 2025).  Trial court affirmed for 80/20 unequal distribution of property, when parties separated 25 years ago and increase in value was due to one owner spouse’s sole efforts, and then erred dividing the debt on the property 50/50 and discounted value by cost of sale when no sale was imminent.  Judge Karen M. Miller reversed.

Silva v. Claffey, 404 So.3d 422 (Fla. 4^th DCA 2025).  Trial court erred using date of trial as valuation date, as opposed to separation date, when there is a sharp increase in value due to one owner spouse’s sole efforts or dramatic decrease in value due to wasteful conduct of owner spouse. Judge Elaine Carbuccia affirmed in part, reversed in part.

Cohen v. Alkobi, 50 Fla.L.Weekly D2666 (Fla. 4^th DCA 2025). Here, the general magistrate set income at $200,000 for temporary relief based on 2023 revenue testimony, credibility findings, historic earnings for corroboration, and the lack of expense proof. The trial court erred by vacating that figure on imputation grounds and because the general magistrate failed to find husband was voluntarily underemployed.  A trier of fact may find that a party earns more than claimed based on testimony and credibility; that is a present-income finding, even if the order uses the word “impute.”  Strong dissent.  Judge Kristin R. Kanner reversed.

Kerrigan v. Page, 401 So.3d 569 (Fla. 2^nd DCA 2024).  Trial court erred failing to address mortgage paydown of premarital property made with marital funds.  Judge Brian Gnage affirmed in part, reversed in part.

Fifth DCA:

Warner v. Warner, 50 Fla.L.Weekly D2185 (Fla. 5^th DCA 2025). Trial court erred charging the husband with depleted retirement accounts that were spent on costs with the divorce, repairs in home, expenses related to medical, and attorney’s fees without wife’s consent, as there was no record of misconduct. Judge R. Gregg Jerald reversed.

Secrist v. Secrist, 50 Fla.L.Weekly D2105 (Fla. 5^th DCA 2025). Trial court erred classifying all of Husband’s retirement as marital, when Husband proved there was a non-marital balance before marriage. Judge Gary L. Wilkinson affirmed in part, reversed in part.

Walsh v. Walsh, 50 Fla.L.Weekly D2682 (Fla. 5^th DCA 2025). Trial court erred assigning a depleted account to Husband based on finding that “Husband was likely cause” of depletion. This does not rise to a specific finding of intentional misconduct regarding a depleted account, which must be included in judgment. Judge Howard Ogle McGillin affirmed in part, reversed in part.

Murnane v. Murnane, 411 So.3d 543 (Fla. 5^th DCA 2025). Trial court erred valuing retirement account  based on accountant’s summary, when no other evidence was presented. Judge Michael J. Rudisill reversed.

Frazier v. Dodd, 406 So.3d 1034 (Fla. 5th DCA 2025). Trial court erred finding wife was part owner who bore cost of continued ownership of the home when husband made a number of mortgage payments. Trial court erred using date of filing to value house and date of trial to value mortgage, as this created unequal distribution. Court erred failing to give husband one-half credit for mortgage payments he made. Judge Brian J. Welke reversed.

Kiswani v. Hafza, 403 So.3d 416 (Fla. 5^th DCA 2025).  Trial court failed to include appropriate findings concerning parties’ assets and liabilities.  Judge Michael J. Rudisill affirmed in part, reversed in part.

Bell v. Bell, 401 So.3d 592 (Fla. 5^th DCA 2025).  Trial court erred by failing to credit husband $10,009 loan he paid on Wife’s vehicle.  Judge James E. Kallaher affirmed in part, reversed in part.

Sixth DCA:

Robinson v. Robinson, 418 So.3d 864 (Fla. 6^th DCA 2025). Trial court erred finding Wife’s transfer of $5k to daughter from another relationship was waste, as there was no evidence that the Wife intentionally depleted a marital asset. Judge Keith P. Spoto affirmed in part, reversed in part.

Exclusive Use and Possession:

Second DCA:

Campana v. Trabold, 403 So.3d 333 (Fla. 2^nd DCA 2024).  Trial court erred granting “no-contact” order which effectively gave Father exclusive use and possession of jointly-owned residence when it was not plead, not noticed, nor tried by consent.  Judge Nancy L. Jacobs reversed.

Income:

Second DCA:

Wilson v. Hurter, 50 Fla.L.Weekly D2117 (Fla. 2^nd DCA 2025). Trial court erred imputing US Census median income of $134k to Wife, when the most Wife ever earned was $105k. Judge William A. Burgess, III affirmed in part, reversed in part.

Fourth DCA:

Thermidor v. Pierre, 419 So.3d 98 (Fla. 4^th DCA 2025). Trial court erred finding wife could not work full-time, when she presented unrebutted evidence that she could not because she had to care for the children. Trial court also erred failing to consider aftercare costs. Judge Cheryl A. Caracuzzo affirmed in part, denied in part.

Fifth DCA:

Warner v. Warner, 50 Fla.L.Weekly D2185 (Fla. 5^th DCA 2025). Trial court erred imputing income to Husband who went from private to public sector voluntarily, because there was no evidence of what Husband could currently make if in private practice, and wife included Husband and adult child’s expenses in her needs. Judge R. Gregg Jerald reversed.

Kiswani v. Hafza, 403 So.3d 416 (Fla. 5^th DCA 2025).  Trial court erred imputing minimum wage to wife without considering F.S. §61.320(2)(b) factors.  Trial court failed to provide required findings for husband’s income to support attached child support guidelines worksheet. Judge Michael J. Rudisill affirmed in part, reversed in part.

Injunctions:

First DCA:

Heule and Huele v. Humphrey, 50 Fla.L.Weekly D2546 (Fla. 1^st DCA 2025). Trial court erred entering stalking injunction based upon posting signs in the window and dressing a skeleton in a way that mocked petitioners without any evidence that petitioners suffered substantial emotional distress. Judge Michael Jones reversed.

Second DCA:

Abercrombie v. Nenneman, 401 So.3d 614 (Fla. 2^nd DCA 2025).  Trial court erred entering stalking injunction when ex-girlfriend 1) called and texted ex-boyfriend several times, 2) appeared at his work several times, 3) followed him after a court hearing crying in a parking lot, because this would not constitute substantial distress to a reasonable person as required.  Judge Linda H. Babb reversed.

Third DCA:

Castano v. Vega, 50 Fla.L.Weekly D2502 (Fla. 3rd DCA 2025). Stalking injunction reversed as findings not supported by competent evidence. Judge Sharon I. Hamilton reversed.

Wages v. Baez, 50 Fla.L.Weekly D2462 (Fla. 3rd DCA 2025). Order dismissing DV injunction petition without prejudice is non-final order that is not subject to appeal as an interim order. Appeal dismissed.

Thompson v. Vilches, 418 So.3d 328 (Fla. 3^rd DCA 2025). Trial court affirmed for denying motion to vacate injunction which was entered after default. Judge Jason A. Reding Quinones affirmed.

Alfonso v. Hierrezuelo o/b/o Z.A., 419 So.3d 279 (Fla. 3^rd DCA 2025). Trial court erred entering injunction based on F.S. 741.30 as opposed to F.S. 784.046, which is what was requested. Trial court based injunction on child hearsay, and F.S. 784.046 requires an eyewitness or direct evidence. Judge Stacy D. Glick reversed.

Lau v. Gonzalez, 412 So.3d 915 (Fla. 3^rd DCA 2025). Injunction can be granted even if there is conflicting evidence. It is up to trial court to determine credibility and resolve conflicts in the evidence. Record contained substantial evidence to support entry of injunction. Judge Linda Melendez affirmed.  Replaces opinion at 50 Fla.L.Weekly D1002.

Lau v. Gonzalez, 412 So.3d 915 (Fla. 3^rd DCA 2025).  Without transcript, appellate court could not resolve the underlying factual issues to determine if injunction was not supported by competent evidence. Judge Linda Melendez affirmed.

Johnson v. Navabi, 409 So.3d 1284 (Fla. 3^rd DCA 2025). Hard to determine if trial court abused discretion when no transcript available, and no stipulated statement of evidence.  Judge Jason A. Reding Quinones affirmed.

Castro v. Guitierrez o/b/o Castro, 408 So.3d 887 (Fla. 3d DCA 2025). Injunction against sexual violence on minor child entered based solely on child hearsay, reversed. Mother was not eyewitness, submitted no direct proof, and failed to submit affidavits of eyewitnesses per Fla. Stat. §784.046(4)(a)(1). Judge Veronica Diaz reversed.

De Jager v. De Jager, 403 So.3d 1061 (Fla. 3^rd DCA 2025).  Final judgment of injunction for protection against domestic violence affirmed when the record supported the wife kicked the husband, and she admitted it on a recorded jail call.  Judge Victoria Del Pino affirmed.

Fourth DCA:

Fletcher-Johnson v. Johnson, 50 Fla.L.Weekly D2447 (Fla. 4th DCA 2025). Cannot seek review of a DV order without transcript. Appellant failed to formally seek other challenged order in notice of appeal, so appellate court did not have jurisdiction to review. Judge Elaine A. Carbuccia affirmed.

Hart v. Moore o/b/o Hart, 418 So.3d 203 (Fla 4^th DCA 2025). Trial court erred denying motion to dissolve injunction, as the Respondent had changed his circumstances by going to anger management and individual therapy, and Petitioner demonstrated no imminent fear as she allowed children to reach out to Father when they wanted to. Judge Elaine Carbuccia reversed.

Beres v. Peterson, 404 So.3d 436 (Fla. 4^th DCA 2025).  Two combined cases. Injunctions obtained by daughters against their mother reversed when record contained no evidence of threat of imminent harm of being a victim of domestic violence. Judge Dina Keever-Agrama reversed on both matters.

Bechert v. Bechert o.b.o. O.B., 408 So.3d 17 (Fla. 4th DCA 2025). Domestic violence injunction entered protecting minor child was improper, when alleged act was form of discipline toward child, and could not put child in fear of being a victim of domestic violence. Judges Susan Lebow and Elaine A. Carbuccia reversed.

Fifth DCA:

Meredith v. Meredith, 50 Fla.L.Weekly D2118 (Fla. 5^th DCA 2025). Trial court should have granted legally sufficient motion to disqualify  when it pre-judged DV case because Wife filed petition in county where she now resides.  Judge Eric C. Roberson reversed.

Rosa v. Heredia, 419 So.3d 331 (Fla. 5^th DCA 2025). Trial court reversed for granting domestic violence injunction, as allegations which included vague allegations of violence over a year ago in another state, and presently Petitioner was just trying to get her mail back. Judge John L. Woodard, III reversed.

Adams v. Cox, 410 So.3d 137 (Fla. 5^th DCA 2025). Domestic violence injunction reversed when record lacked evidence of imminent harm, and trial court denied Petitioner his due process by not letting him present evidence.  Judge Matthew M. Foxman reversed.

Blake v. Fares, 50 Fla.L.Weekly D629 (Fla. 5th DCA 2025). Email the respondent sent to multiple classmates that gave his version of events that led to parties’ divorce that did not threaten violence could not form basis for injunction. Judge Eric Roberson reversed.

Sixth DCA:

Marcionette v. Marcionette, 50 Fla.L.Weekly D1949 (Fla. 6^th DCA 2025). Trial court erred for denying motion to dissolve injunction for lack of jurisdiction, when motion was filed in wrong division. Judges Diana M. Tennis and Barbara J. Leach reversed.

Harrington v. Giancola, 415 So.3d 845 (Fla. 6^th DCA 2025). Domestic violence injunction supported by competent substantial evidence was affirmed.  Judge Andrew Marcus affirmed.

Schmigel v. Schmigel, 404 So.3d 623 (Fla. 6th DCA 2025). Trial court did not violate respondent’s due process rights by allowing sixteen-year-old child to attend and testify at hearing without an order authorizing it as required by the rules. To satisfy due process requirement at an injunction hearing, the parties must have a reasonable opportunity to prove or disprove the allegations made in the complaint, which includes allowing relevant testimony of pertinent non-cumulative witnesses who are present and cross-examination by the other side. Rule 12.407(a) was promulgated to protect children, not expand due process rights. Judge Dawn Caloca-Johnson affirmed.

Jurisdiction:

Third DCA:

Niemeyer v. Niemeyer, 409 So.3d 186 (Fla. 3^rd DCA 2025). When Florida court had parallel proceedings with Turkey, Florida court properly denied antisuit injunction. General rule is when concurrent jurisdiction exists, each forum may proceed to final judgment. Judge Stacey D. Glick affirmed.

Justice v. Guerrero-Justice, 403 So.3d 375 (Fla. 3^rd DCA 2025).  Parties filed dueling divorces in Florida and Tennessee.  Order dismissing Florida action and finding Tennessee was the child’s home state reversed when Florida judge conducted UCCJEA conference with Tennessee judge without providing notice or opportunity to participate.  Wife’s argument that participation only happens when a party affirmatively elects to participate was not a fair reading of the statute. Judge Bonnie J. Helms reversed.

Fourth DCA:

Bechert v. Bechert o.b.o. O.B., 408 So.3d 17 (Fla. 4th DCA 2025). UCCJEA does not apply if parties do not dispute custody of a minor child. Judge Christina Marie DiRaimondo affirmed.

Carrasco v. Jimenez, 419 So.3d 640 (Fla. 4th DCA 2025). Wife petitioned for divorce. Court granted husband’s motion to dismiss because the husband alleged the parties were divorced in Venezuela and domesticated a Venezuelan final judgment. Trial court erred granting motion to dismiss because wife’s petition did not mention the Venezuelan divorce and allegations must be deemed admitted. Trial court must review foreign judgment to ensure it complies with the rule of comity. Here Venezuelan court did not have personal or subject matter jurisdiction over wife, so domestication order also reversed. Judges Dale C. Cohen and Kristin R. Kanter, reversed.

Fifth DCA:

Aluise v. Aluise, 50 Fla.L.Weekly D2316 (Fla. 5^th DCA 2025). Trial court erred for dismissing petition to modify Pennsylvania decree granting partial grandparent custody.  Pennsylvania has broader grandparent visitation rights than Florida.  Case was domesticated in Florida by consent, as parents moved to Florida.  While full faith and credit given to Pennsylvania order, parents had right under UCCJEA to modify. Judge Russell L. Healey reversed.

Life Insurance:

Fourth DCA:

Alfonso v. Alfonso, 50 Fla.L.Weekly D1043 (Fla. 4^th DCA 2025). Trial court reversed for requiring alimony to be secured with life insurance, as there were no findings as to cost or availability.  Leatha D. Mullins affirmed in part, reversed in part.

Fifth DCA:

Woodlief v. Woodlief, 415 So.3d 1208 (Fla. 5^th DCA 2025). Trial court failed to find any special circumstances in ordering life insurance, and erred ordering an amount of security that exceeded obligations. Judge Suzanne Bass affirmed in part, reversed in part.

Modification:

Second DCA:

Dorsett v. Schexnayder, 50 Fla.L.Weekly D919 (Fla. 2^nd DCA 2025). Trial court abused discretion by sua sponte modifying Former Husband’s right to claim federal tax exemption for child when relief was not requested.  Judge Thomas N. Palermo affirmed in part, reversed in part.

Third DCA:

Restrepo v. Aquino, 407 So.3d 535 (Fla. 3d DCA 2025). Order dismissing modification affirmed when grounds did not allege a substantial change in circumstances. Judge David Young affirmed.

Fifth DCA:

Squires v. Squires, 415 So.3d 263 (Fla. 5^th DCA 2025). Trial court is not required to make findings of fact when denying a petition to modify a parenting plan. Judge Bernard S. Shapiro affirmed.

Name Change:

Fourth DCA:

In Re: M.T.F., 401 So.3d 367 (Fla. 4^th DCA 2025).  Trial court affirmed for denying name change of minor child, when petition failed to describe how it was in child’s best interest.  Trial court reversed for denying motion for rehearing which did.  Judge Karen M. Miller affirmed in part, reversed in part.

Parenting:

Third DCA:

Hernandez ,50 Fla.L.Weekly D2527 (Fla. 3^rd DCA 2025). Trial court erred temporarily restricting parent’s timesharing at a CMC based on allegations of parental alienation where this was not noticed for hearing. Judge Scott M. Bernstein reversed.

Lawler v. Lawler, 412 So.3d 939 (Fla. 3^rd DCA 2025). Trial court affirmed for granting temporary relocation for Father and son to relocate to South Carolina without an evidentiary hearing, because Father was ordered to relocate because he is in Coast Guard.  Father had 305 overnights and Mom had summers, and therefore Father’s relocation did not impact timesharing.  Mother argued Father’s petition to relocate was legally insufficient as it failed to provide a post-relocation timesharing schedule and proposal for transportation costs.    Mother failed to respond/object to petition in 20 days, which justifies entry of order without an evidentiary hearing. Mother attempted to argue that best interests standard precludes determination merely on default, but order is clear that Court considered child’s best interests. Judge Luis Garcia, affirmed.

Alan v. West, 420 So.3d 566 (Fla. 3^rd DCA 2025). Trial court affirmed for modifying parental responsibility when issue tried by consent. Judge Ivonne Cuesta affirmed. 

Malek v. Malek, 414 So.3d 381 (Fla. 3^rd DCA 2025).  Paternity order that significantly limited Father’s timesharing was affirmed when order was supported by competent evidence.  Judge Christina Marie DiRaimondo affirmed.

Salazar v. Blanco, 411 So.3d 1271 (Fla. 3^rd DCA 2025).Even without trial transcript, paternity final judgment reversed when there was no parenting plan, and only finding concerning child was shared parental is in child’s best interest. Although F.S. 61.13(3) does not require written findings justifying a custody award, the record must at least demonstrate that F.S. 61.13 factors were considered. Judge Marcia Del Rey reversed and remanded.

Verdasco v. Vazquez, 405 So.3d 496 (Fla. 3d DCA 2025). Trial court’s award of ultimate decision-making authority as to education and healthcare affirmed when supported by the record. Judge George A. Sarduy affirmed

Mishkin v. Mishkin, 407 So.3d 536 (Fla. 3d DCA 2025). Order temporarily suspending timesharing affirmed when there was a true emergency. Judge Veronica Diaz affirmed.

Sala v. Wood, 406 So.3d 339 (Fla. 3d DCA 2025). Trial court affirmed after restoring parent’s timesharing after full hearing where all parties had notice and court properly considered all evidence. Judge Victoria Del Pino affirmed.

Fourth DCA:

Luna v. H Lally v. Lally, 50 Fla.L.Weekly D2620 (Fla. 4^th DCA 2025). Trial court erred allowing modification as non-custodial parent’s voluntary move alone is insufficient to support modification. Judge Anastasia M. Norman reversed.

Wilson v. Martin 50 Fla.L.Weekly D2454 (Fla. 4^th DCA 2025). Trial court erred including a prospective relocation timesharing default provision and allowing Father to pick up child from school where Mother worked, when a DV injunction was in place. Judge Sara Alijewicz affirmed in part, reversed in part.

Fifth DCA:

Keck v. Fortier, 414 So.3d 396 (Fla. 5^th DCA 2025).  Trial court erred, even without transcript, awarding majority timesharing to one party without making findings of fact regarding 61.13 factors, and awarding sole parental responsibility when same was not requested.  Judge Michael Takac reversed. 

Murnane v. Murnane, 411 So.3d 543 (Fla. 5^th DCA 2025). Trial court’s summer timesharing schedule reversed because it could cause confusion and begs for chaos. Parties had week on/week off timesharing, and Court allowed them to take one-week, or a two-week continuous vacation in summer. This could cause 5 straight weeks of children with same parent. Judge Michael J. Rudisill reversed.

Kiswani v. Hafza, 403 So.3d 416 (Fla. 5^th DCA 2025).  Trial court’s parenting plan reversed when it 1) failed to implement a timesharing schedule, 2) delegated authority for court to review timesharing only by recommendation of a third party, giving therapist authority to establish visitation and guidelines, and 3) impermissibly established conditions for mother to regain timesharing with child.  Judge Michael J. Rudisill affirmed in part, reversed in part.

Rosado v. Samuelsen, 401 So.3d 606 (Fla. 5^th DCA 2025).  Trial court made oral pronouncement that it would include a provision in parenting plan that child must be administered prescribed.  Such final judgment was reversed when it failed to include this provision.  Judge Brian J. Welke affirmed in part, reversed in part.

Sixth DCA:

Wolverton v. Wolverton, 50 Fla.L.Weekly D2525 (Fla. 6^th DCA 2025). Trial court erred by failing to make findings on F.S. 61.13(3) custody factors when awarding shared parental responsibility, especially when abuse allegations were raised at trial. Judge Keith P. Spoto affirmed in part, reversed in part.

Partition:

First DCA:

Lantz v. Gibson, 50 Fla.L.Weekly D2543 (Fla. 1^st DCA 2025). Trial court erred not crediting former husband with one-half of expenses that were necessary to maintain ownership of home, with the exception of the mortgage payment which the MSA provided the former husband would pay. Judge John J. Gontarek reversed.

Fifth DCA:

Diaz v. Nolan, 50 Fla.L.Weekly D677 (Fla 5th DCA 2025). Courthouse auction of property reversed where parties agreed to private sale remanded to allow time for parties to effectuate private sale. If not done by specified time, judicial sale will take place. Judge Russell L. Healey affirmed in part, reversed in part

Paternity:

First DCA:

Schauer v. Mitchell, 401 So.3d 627 (Fla. 1^st DCA 2025).  Trial court’s non-final order affirmed, finding father’s paternity had been established and denying pick-up order because amended F.S. §744.301(1) now establishes paternity when father is on birth certificate and Mom signed voluntary acknowledgment of paternity at child’s birth.  Judge Frederick Laurence Koberlein, Jr. affirmed.

Third DCA:

Rosich-Medina v. Chilaud, 50 Fla.L.Weekly D2577 (Fla. 3^rd DCA 2025). Trial court erred ordering genetic testing before determining whether that would be in child’s best interest, when child already had a legal father. Judge Diana Vizcaino’s order allowing genetic testing quashed.

Fourth DCA:

Bronner v. Longden, 398 So.3d 1015 (Fla. 4^th DCA 2024).  Trial court erred making findings of fact without an evidentiary hearing and dismissing potential legal father’s paternity action when allegations in petition should have been taken as true for purposes of a motion to dismiss.  Matter remanded for evidentiary hearing to determine if acknowledgement of paternity should be voided due to fraud, duress, or mistake of fact.  Judge Darren Shull reversed.

Fifth DCA:

Bauer v. Carlson, 408 So.3d 155 (Fla. 5th DCA 2025). Trial court properly denied potential biological father’s motion to intervene and motion to disestablish paternity. Trial court did err dismissing it with prejudice when it announced it would dismiss without prejudice. Judge Thomas R. Eineman affirmed in part, reversed in part.

Procedure:

First DCA:

Franklin v. Franklin, 50 Fla.L.Weekly D2173 (Fla. 1^st DCA 2025). Writ of prohibition to restrain local judge from presiding over matter is granted, because trial judge erroneously concluded they were successor judge when previous magistrate was disqualified. That should not have triggered successor judge burden on motion to withdraw circuit judge. 

Gooch v. Cohen, 413 So.3d 293 (Fla. 1^st DCA 2025). Pro se appeal treated as a writ of mandamus, which was granted and required trial court to hold a hearing on petition for modification.

Second DCA:

Stamler v. Stamler, 407 So.3d 1265 (Fla 2d DCA 2025). Trial court denied party’s due process by stopping hearing scheduled for an hour after an hour had passed, without allowing the party to testify and present evidence on a contested issue. Judge Wendy DePaul reversed.

MacKenzie v. MacKenzie, 50 Fla.L.Weekly D2518 (Fla. 2^nd DCA 2025). Writ of prohibition granted to remove Judge whose findings concerning counsel’s mental health, fitness to practice and candor, establish clear bias. Writ of prohibition issued against Judge Brian Edward Gnage.

Wiendl v. Wiendl, 403 So.3d 349 (Fla. 2^nd DCA 2025). Trial court went too far restraining litigious pro-se party from filing papers without an attorney’s signature, and requiring mediation and making the pro se party pay for mediation whenever there were 3 motions pending, without providing litigant with notice and an opportunity to be heard.  Barring a self-represented litigant from filing papers is strong medicine.  Writ of certiorari granted, and Judge Wesley D. Tibbals order quashed.

Cirillo v. Cirillo, 408 So.3d 131 (Fla. 2d DCA 2025). Trial court failed to include parties’ stipulation on support arrears, and failed to reserve jurisdiction to adjudicate timely filed charging lien. Judge Alicia Polk affirmed in part, reversed in part.

Bonsignori v. Boulay, 402 So.3d 434 (Fla. 2^nd DCA 2024).  Trial court affirmed for denying 12.540(b)(5) “new circumstances” motion when facts do not amount to new circumstances occurring post-judgment.  Judge Steve D. Berlin affirmed.

Third DCA:

Viera v. Viera, 412 So.3d 194 (Fla. 3^rd DCA 2025). Trial court erred dismissing matter for lack of prosecution without providing notice required by 12.420. Judge Oscar Rodriguez-Fonts reversed.

Wax v. Friedman, 50 Fla.L.Weekly D2357 (Fla. 3^rd DCA 2025). Entire final judgment void when no corroborating evidence of residency. Judge David Young reversed.

Rodriguez v. Gonzalez, 415 So.3d 309 (Fla. 3^rd DCA 2025). Trial court granted motion to vacate magistrate’s order for lack of substantial evidence.  Court then entered magistrate’s order.  This suggests trial court might have used too differential of a standard, so matter remanded to use correct standard to evaluate motion to vacate. Judge Stacy D. Glick reversed.

Bouquet v. Jones, 408 So.3d 869 (Fla 3d DCA 2025). A series of adverse rulings and the requirement that proceedings must be live as opposed to held on Zoom is not sufficient to support disqualification of the judge.  Writ of prohibition against two trial judges denied.

Smith v. Smith, 406 So.3d 521 (Fla. 3d DCA 2025). Trial court affirmed for denying eleventh hour request for continuance and referring support matter to judicial magistrate. Judge Jason E. Dimitris affirmed.

Greenwood v. Greenwood, 406 So.3d 973 (Fla. 3^rd DCA 2025).  Trial court violated former wife’s due process by awarding temporary decision-making authority regarding child’s education when 1) relief not requested in motion, 2) former husband previously made this request and it was denied, 3) option not discussed at hearing, and 4) former wife did not have notice and opportunity to be heard.  Judge Marlene Fernandez-Karavetsos reversed.

Oria v. Velastegui, 402 So.3d 427 (Fla. 3^rd DCA 2024).  Trial court erred dismissing a modification seeking to adjudicate issues that were not addressed in original paternity judgment because in this case, the Mother defaulted and because of that, the Court had to assume father’s allegation of substantial change of circumstances was deemed admitted.  Court affirmed for dismissing request for holiday timesharing as that had been addressed in the final judgment.  Judge Marcia Del Ray affirmed in part, reversed in part.

Pardes v. Pardes, 404 So.3d 543 (Fla. 3^rd DCA 2025).  Writ of prohibition granted to prevent circuit court judge from determining amount of attorney’s fees already awarded, when parties agreed all litigation will be adjudicated by a private judge. 

Phinney v. Phinney, 50 Fla.L.Weekly D207 (Fla. 3^rd DCA 2025).  Husband’s sister was his guardian after traumatic head injury, and also his attorney in his divorce. Trial court erred disqualifying the sister/guardian/attorney as the attorney for the husband, when sister/guardian/attorney was going to be a witness at final hearing.   Disqualifying sister/guardian/attorney was too broad.  Sister/guardian/attorney should only be prohibited from being attorney at hearing she would be a witness.  Judge Marlene Fernandez-Karavetsos reversed.

Fourth DCA:

Capps v. Capps, 50 Fla.L.Weekly D2664 (Fla. 4^th DCA 2025).  Trial court affirmed for emergency suspension of Wife’s timesharing without notice or a hearing.  Florida caselaw has recognized that in very limited situations a trial court can modify prior custody orders on an emergency basis for the protection of the children, and without a full evidentiary hearing. Fourth DCA clarified that emergencies are not limited to physical harm or improper removal of children from the jurisdiction. Judge Kristin R. Kanner affirmed.

Bryan v. Bryan, 50 Fla.L.Weekly D2619 (Fla. 4^th DCA 2025). Trial court reversed for issuing parenting plan that did not have specific timesharing provisions, methods of how parent will communicate with child, and failed to make necessary jurisdictional findings. Judge Lauren Alperstein affirmed in part, reversed in part.

Bui v. Panzardi, 416 So.3d 1158 (Fla. 4^th DCA 2025). Trial court erred failing to address child support even though neither party objected, as it is “fundamental error” not to address. Judge Lorena Mastrarrigo affirmed in part, reversed in part.

Graydus v. Graydus, 414 So.3d 213 (Fla. 4^th DCA 2025). Trial court erred rendering final judgment that conflicted with oral pronouncements.  Judge ruled Wife had to reimburse Husband for utility bill. Trial court erred by conditioning such payment on Husband presenting bill within 10 days in final judgment entered, when that was not included in the oral pronouncement. Judge Sherwood Bauer affirmed in part, reversed in part.

Fifth DCA:

Tucker v. Tucker, 409 So.3d 699 (Fla 5th DCA 2025). Former wife sought relief from QDRO order on Florida Retirement System that had an additional paragraph that eliminated former wife’s enforcement to DROP benefits. Motion filed by former wife more than a year after entry of the order. Rule 12.540(a) does not apply here, because it does not allow for substantive changes. Rule 12.540(b) does not apply here, because motion filed more than a year after entry. Judge Michelle T. Morley reversed.

Ramirez v. Gregory, 403 So.3d 414 (Fla. 5^th DCA 2025).  Trial court reversed for awarding retroactive support when issue was not raised by pleadings, nor tried by consent.  Judge Thomas R. Eineman affirmed in part, reversed in part.

Sixth DCA:

Sanzaro v. Crowe, 412 So.3d 858 (Fla. 6th DCA 2025). In domestic violence case, trial court did not abuse discretion in denying motion to appear by Zoom. Judge John S. Carlin affirmed.

Supreme Court:

In Re: Amendments to the Florida Family Law Rule of Procedure – Forms, 50 Fla.L.Weekly S139 (Fla. 2025).  Revisions to several family law forms, including mandatory disclosure and long-form financial affidavit.

In Re: Amendments to the Florida Family Law Rule of Procedure – Forms, 50 Fla.L.Weekly S119 (Fla. 2025).  Adds requirement to file and serve each party with notice to parties of issuance of subpoena on the same day subpoena is issued.

Relocation:

Second DCA:

Burgess v. Burgess, 399 So.3d 1290 (Fla. 2^nd DCA 2025).  Non-final order denying temporary petition to relocate affirmed as record demonstrated move was not in minor child’s best interest. Judge Nancy L. Jacobs affirmed.

Third DCA:

Dunn v. Flores, 50 Fla.L.Weekly D2576 (Fla. 3^rd DCA 2025).  Stay granted and trial court mandated to reconsider emergency motion for return of child.  Trial court erroneously concluded child was improperly relocated to another state.  Florida’s relocation statue is inapplicable to a relocation occurring before filing.  Order stayed and Jurisdiction relinquished for Judge George A. Sarduy’s order, to reconsider motion within 30 days.

Blakeslee v. Madrigal, 50 Fla.L.Weekly D2576 (Fla. 3^rd DCA 2025). Judgment finding relocation in child’s best interest affirmed. Judge Christina Marie DiRaimondo affirmed.

Puertas v. Ruiz, 50 Fla.L.Weekly D2541 (Fla. 3^rd DCA 2025). Final judgment allowing relocation affirmed when there is no transcript and no error on face of judgment.  Judge Spencer Multack affirmed.

Harman v. Alonso, 50 Fla.L.Weekly D2361 (Fla. 3rd DCA 2025). Trial court erred by relying on impermissible findings and erroneously applied a presumption against relocation. Judge Spencer Multack reversed.

Gevaert v. Teh, 50 Fla.L.Weekly 2066 (Fla. 3^rd DCA 2025). Trial court affirmed for ruling contrary to expert’s opinion that California has better schools, as the Court is required to consider a wider range of factors. Judge Spencer Multack affirmed.

Greenwood v. Greenwood, 406 So.3d 973 (Fla. 3^rd DCA 2025). Trial court affirmed for properly weighing and analyzing relocation factors. Judge Marlene Fernandez-Karavestos affirmed.

Sanctions:

Sixth DCA:

Clerk of Hillsborough County v. Rangel, 50 Fla.L.Weekly D1945 (Fla. 6^th DCA 2025). Non-family case. Attorney sanctioned for using AI, and referred to Florida Bar.

Support:

First DCA:

Second DCA:

Mullarkey v. Tiraco, 417 So.3d 475 (Fla. 2^nd DCA 2025). Final judgment awarding support reversed when guidelines not attached. Appellate court explains retroactive support does not mean the same as arrearages. Judge Brian Gnage affirmed in part, revered in part.

Third DCA:

Noss v. Noss, 50 Fla.L.Weekly D2299 (Fla. 3^rd DCA 2025). Numbers in guidelines were not tethered to former wife. Remanded for court to determine gross income, then arrive at net income by determining deductions. Judge Marcia Del Rey affirmed in part, reversed in part.

Perez-Palma v. Rodriguez, 413 So.3d 866 (Fla. 3^rd DCA 2025). Even without transcript, trial court erred requiring husband to pay 100% of cost of supervised timesharing. Other alleged errors could not be considered due to lack of transcript. Judge Scott M. Bernstein affirmed in part, reversed in part.

Alvarez v. Stochetti, 406 So.3d 1007 (Fla 3d DCA 2025). Trial court erred basing child support on 70/30 timesharing, when it was 65/35, and erred for requiring support to be guaranteed by life insurance without finding of special circumstances. Judge David Young, affirmed in part, reversed in part.

Phara v. Robert, 406 So.3d 983 (Fla. 3d DCA 2025). Father appealed support order alleging mother did not provide mandatory discovery. The argument was meritless because the record proved otherwise. Judge Veronica Diaz affirmed.

Aguirre v. Andrukiebich, 405 So.3d 480 (Fla. 3d DCA 2025). Even without a transcript, inconsistencies between the order and child support guidelines required reversal. However, appellate court could not review any other alleged errors without a transcript. Judge Samantha Ruiz Cohen, affirmed in part, reversed in part.

Fourth DCA:

Morrell v. Alsentzer, 415 So.3d 708 (Fla. 4^th DCA 2025). Fact child turned 18 did not prevent party from seeking child support from date of filing until child’s 18^th birthday. Judge Rosemarie Scher reversed. 

Nicholas v. Nicholas, 405 So.3d 363 (Fla. 4th DCA 2025). Trial court reversed for not attaching child support guidelines, failing to use husband’s imputed income to calculate support, and failing to require a party to provide health insurance. Judge Elaine A. Carbuccia affirmed in part, reversed in part.

Smith v. Chevillet, 403 So.3d 230 (Fla. 4^th DCA 2025).  Trial court failed to add alimony received to recipient’s income for purposes of calculating child support.  Judge Darren Shull reversed.

Fifth DCA:

Tucker v. Adams, 50 Fla.L.Weekly D2190 (Fla. 5^th DCA 2025). Trial court erred by not making custody findings and determining net incomes, even without a transcript. However, Husband could not challenge issues he claimed were tried but not plead without a transcript, as it cannot be determined if matter was tried by consent. Judge Stasia Warren reversed.

Gilberts v. Manderino-Gilberts, 416 So.3d 1183 (Fla. 5^th DCA 2025). Trial court improperly changed amount of child support agreed on by parties, and deviated from guidelines without findings of fact. Judge Kathryn M. Speicher reversed.

Lucombe v. Lucombe, 412 So.3d 197 (Fla. 5^th DCA 2025). Trial court erred requiring former husband to pay $43,200 in retroactive support at $50 per month.  The trial court cannot order lump sum without evidence of ability to pay.  That said, $50 a month without explanation is unsupportable. Judge John I. Guy affirmed in part, reversed in part.

Hunter v. Hunter, 406 So.3d 1122 (Fla. 5th DCA 2025). Trial court erred basing child support on parties’ gross incomes. Judge Lester Bernard Bass affirmed in part, reversed in part.

Favela v. Ramtahal, 402 So.3d 457 (Fla. 5^th DCA 2025).  Even without transcript, trial court erred by failing to use party’s actual income to determine retroactive support.  Judge Ann Melinda Craggs affirmed in part, reversed in part.

Sixth DCA:

DOR v. Serwe, 50 Fla.L.Weekly D2483 (Fla. 6th DCA 2025). Although striking DOR’s notice of redirection and order requiring mother to pay support directly to Father was error, DOR waived appeal by not seeking to vacate order generated by magistrate. Judge Elaine A. Barbour reluctantly affirmed. 

J.E.J. v. S.A.B., 416 So.3d 1186 (Fla. 6^th DCA 2025).  Trial court reversed because it included pass-through income in determining income, instead of considering the amount actually distributed. Certified conflict with Blair v. Blair, 214 So.3d 750 (Fla. 2^nd DCA 2017) and McHugh v. McHugh, 702 So.2d 639 (Fla. 4^th DCA 1997).  Explains Zold stands for proposition of “corporate purpose” test for retained earnings. When issue of whether income properly retained for “corporate purpose” rather than shielding it from an award of alimony. Judge Christine H. Greider reversed in part, conflict certified.

Frantz v. Crawford-Frantz, 415 So.3d 783 (Fla. 6^th DCA 2025). Trial court erred awarding retroactive support for periods of time in which the parties resided together. Judge Lisa S. Portier affirmed in part, reversed in part.

Garwood v. Garwood, 412 So.3d 126 (Fla. 6^th DCA 2025). Even without transcript, judgment modifying support and determining arrearages reversed due to computational errors on face of judgment. Judge Michael Kraynick affirmed in part, reversed in part.

Temporary Relief:

Fourth DCA:

Strolla v. Strolla, 406 So.3d 367 (Fla. 4th DCA 2025). Temporary relief order reversed when court ordered husband to pay certain expenses but presented no evidence of how husband could pay those expenses. Judge Dina Keever-Agrama reversed.

Summary of 2025 Florida Disciplinary Proceedings

1. Permanent disbarment

• Jean Gerard Legagneur, Jr. — permanently disbarred (SC2023-1583) — Why: Pled guilty to issuing a false financial statement (intent to defraud) and executed affidavits confessing judgment for victim losses.

2. Disciplinary revocation — without leave to seek readmission

• Sonya Charmaine Davis — revocation w/o leave (SC24-1613) — Why: Neglected matters, failed to appear in court settings, and a small-claims court found she forged a State Attorney representative’s signature on an FDLE form.
• Alex S. Barnett — revocation w/o leave (SC2025-0083) — Why: Social media/communications and related conduct led to multiple felony charges and a nolo contendere plea.
• Patricia Anne Bronson — revocation w/o leave (SC2025-0085) — Why: Petitioned for revocation after criminal cases including felony contraband introduction and reckless-driving-related probation terms.
• Gregory F. Pillon — revocation w/o leave (SC2025-0319) — Why: Allegedly worked in a real estate transaction and gave legal advice while disbarred (UPL-type conduct) and failed required reporting.
• Paul Gerard Wersant — revocation w/o leave (SC2025-0944) — Why: Petitioned for revocation while a disciplinary case was pending arising from felony convictions (false documents and custody-interference counts).
• Rugh J. Cline — revocation w/o leave (SC2025-1235) — Why: Adjudicated guilty of illegal sexual conduct in a foreign place (18 U.S.C. § 2423(c)).

3. Disbarment with extended re-application window (10 years)

• Roberto Masud — disbarred; reapply in 10 years (SC22-0768) — Why: As escrow agent, disbursed/transferred $864,000 from trust contrary to escrow terms and to non-parties.

4. Standard disbarment

• Mercedes Gonzalez Hale — disbarred (SC24-0431) — Why: Abandoned clients and failed to participate, with prior discipline for failing to respond to Bar inquiries.
• Debbie Rachelle Campbell — disbarred (SC24-1563) — Why: Continued practicing law while suspended and after contempt/suspension for failing to comply with a trust-records subpoena.
• Daryl Bobby Fenton — disbarred (SC24-1048) — Why: Practiced while delinquent, misrepresented that on reinstatement paperwork, then failed to respond/appear in discipline proceedings.
• Andrea Povilaitis — disbarred (SC24-0811) — Why: Concealed neglect by falsely claiming a settlement and paying “settlement funds” from personal money, then misled the Bar and failed to participate.
• Danialle Riggins — disbarred (SC24-0817) — Why: Serious pattern of neglect/noncommunication across multiple clients, took fees for no useful services, and failed to meaningfully participate.
• Thomas Arthur Chandler — disbarred (SC24-1675) — Why: DUI third/subsequent felony conviction (no contest; adjudicated guilty) led to ultimate disbarment.
• Malik Leigh — disbarred (SC2023-0518) — Why: Threatening posts and baseless accusations in litigation plus repeated failure to prosecute viable pleadings and comply with court orders.
• Chance McClain — disbarred (SC2024-0917) — Why: Willfully violated disqualification orders by continuing to act as counsel and filing/advising in defiance of court rulings.
• Jeffrey Marc Siskind — disbarred (SC23-0566) — Why: Misappropriated large sums from two clients.
• Thomas Grant Neusom — disbarred (SC2025-0122) — Why: Repeatedly failed to respond to Bar inquiries and a Supreme Court show-cause order, resulting in contempt and disbarment.
• Todd J. Herman — disbarred (SC2025-0228) — Why: Failed to account for/deliver client funds, failed to keep clients informed, and failed to respond to Bar inquiries.
• Alejandro L. Marriaga — disbarred (SC2024-1241) — Why: Misdirected closing funds, violated trust-account rules, concealed conflicts, and diverted builder draws so homes were never constructed.

5. Disciplinary revocation — with leave to seek readmission

• David Michael Carnright — revocation w/ leave after 5 years (SC24-1668) — Why: Petitioned for revocation following felony suspension (granted by the Court).
• Jerrod Mackenzie Paul — revocation w/ leave (SC24-1520) — Why: Told client case was settled and had her sign releases, but allegedly failed to pay providers and mishandled closing/disbursement steps.
• Larry Edward Powers, Jr. — revocation w/ leave (SC24-1535) — Why: Trust-account shortages and commingling.
• Nicole Marie Pearl — revocation w/ leave after 5 years (SC24-1814) — Why: Petitioned for revocation after a judicial finding of fraudulent conduct tied to a real estate development project.
• Charles Wade Price — revocation w/ leave after 5 years (SC25-0126) — Why: Misappropriated client-provided funds meant for the bankruptcy trustee, abandoned practice, and was suspended in bankruptcy court.
• Lisa Renee Wilcox — revocation w/ leave after 5 years (SC25-0093) — Why: Conflict-of-interest conduct adverse to a co-owner client and failure to supervise spouse’s access to firm emails.
• Dorothy Kim Hufnagel — revocation w/ leave (SC2025-0890) — Why: Neglected dissolution cases, took fees without work in at least one case, and was jailed for civil contempt (alimony nonpayment).
• Stephen Everett Walker — revocation w/ leave (SC2025-0946) — Why: Civil contempt and abusive/frivolous litigation conduct plus related legal issues (per the Bar summary).
• Richard Gonzalez — revocation w/ leave after 5 years (SC2025-1280) — Why: Misappropriated trust funds and failed to reimburse the client.
• Michelle Lee Farkas — revocation (SC2025-1207) — Why: Took a trust retainer, misrepresented status for ~3.5 years, never filed the case, and later refunded the retainer.

6. Emergency suspension / “until further order” / contempt-based indefinite suspensions

• Xenia Hernández — emergency suspended (SC2025-0556) — Why: Alleged misappropriation and major trust-account shortages (six figures) with improper disbursements using other clients’ funds.
• Jay Lewis Farrow — suspended until further order (emergency) (SC2025-0863) — Why: Alleged abandonment, excessive fees for no services, bad-faith tactics, and fraudulent court filings.
• Rawsi Williams — suspended until further order (emergency) (SC2025-1037) — Why: Alleged misappropriation of client trust funds leading to frozen trust accounts.
• Michael Alexander Hurckes — emergency suspended until further order (SC2025-1375) — Why: Alleged ongoing, widespread misconduct posing immediate/serious harm risk to clients/public.
• Ryan Thomas Kraus — contempt + suspended until compliance (SC2024-1569) — Why: Failed to respond to Bar inquiry and then ignored the Supreme Court’s order to show cause.
• Paige Sundance Mincieli — suspended until further order (SC2025-1188) — Why: Failed to respond to multiple Bar inquiries and a Supreme Court show-cause order.
• Nabil Ibrahim Abu Nahlah — suspended until further order (SC2025-1370) — Why: Pled guilty to major fraud against the United States (federal case).
• Larry Edward Powers III — contempt + suspended until response/further order (SC2025-1114) — Why: Held in contempt for failing to respond to Bar investigative inquiries and a Supreme Court show-cause order.
• Jeffrey Rice Hussey — suspended (SC2025-1424) — Why: Failed to respond to an official Bar inquiry leading to contempt/show-cause proceedings (per summary).
• Jennifer Anne Tanck — suspended (SC2025-0790) — Why: Failed to respond to an official Bar inquiry and then failed to respond to the Supreme Court’s show-cause order.
• Susan Rachel Torres — suspended (SC24-1558) — Why: Failed to file a response to the Supreme Court’s order to show cause.

7. Interim felony suspension

• Kenneth Chesebro — interim felony suspension (SC24-1528) — Why: Pled guilty to a felony conspiracy count related to filing false documents (Georgia election-interference case).
• Kirk Bradley Reams — interim felony suspension (SC24-1439) — Why: Convicted of second-degree felony grand theft (over $20,000).
• Gabriel F.V. Warren — interim felony suspension (SC24-1206) — Why: Pled nolo contendere to unlawful use of a communications device to facilitate a felony.
• Sarah Savannah Warren — interim felony suspension (SC24-1208) — Why: Same—pled nolo contendere to unlawful use of a communications device to facilitate a felony.
• Kathryn Wilburn Drey — interim felony suspension (SC2025-1644) — Why: Charged and pled guilty to a federal felony involving acts affecting a personal financial interest.

8. Felony suspension

• Paul Gerard Wersant — felony suspension (SC25-0455) — Why: Pled guilty to Georgia felonies including interstate custody interference and filing false documents.
• Christopher Rodriguez — felony suspension (SC2025-1452) — Why: Federal felonies involving explosives/destructive device conduct and damage to foreign-government-occupied property; sentenced to prison.
• David Casals — felony-conviction suspension (SC2025-1538) — Why: Jury conviction for felony cocaine possession and misdemeanor contraband introduction (referee to recommend final sanction).
• Billy-Joe Hoot Crawford — felony suspension (SC2025-1715) — Why: Convicted of felony interference with custody and felony witness/victim/informant tampering.
• Thomas Arthur Chandler — suspended immediately (earlier) (SC24-1675) — Why: Felony DUI third/subsequent conviction triggered immediate suspension before later disbarment.

9. Fixed-term suspensions (ranked by length)

• 3 years
  • Claudia M.E. Atkinson — 3-year suspension (SC2024-0940) — Why: Work/behavioral issues impacting practice plus failure to respond and failure to participate in discipline proceedings.
  • Charles David Franken — 3-year suspension (SC24-1298) — Why: Criminal conduct tied to a closing-agent role (pled no contest to petit theft; restitution ordered).
  • Jeffrey Barnes — 3-year suspension (SC2024-1832) — Why: Reciprocal discipline plus Florida misconduct including dishonesty, judge-impugning statements, court-order violations, neglect, and fee/refund issues.
  • Stephen Everett Walker — 3-year suspension (earlier) (SC2023-1205) — Why: Filed and disseminated humiliating/harassing pleadings and made false RICO-type accusations in litigation against a former partner and others.
• 2 years
  • Suzanne DeWitt — 2-year suspension (SC2024-1692) — Why: Discipline arose from a civil court order finding breach of fiduciary duties involving corporate-structure manipulation/false info in real estate transactions.
  • Maurice DeShawn Hinton — 2-year suspension (SC2024-0453) — Why: Neglect/noncommunication, sexual relationship with a client followed by neglect, practiced while delinquent, and failed to respond in proceedings.
  • Kevin T. Vagovic — 2-year suspension (SC2024-1815) — Why: Sexualized messages to a client, failed to appear at hearings/trial, and failed to maintain communication in two matters.
  • Larry Elliot Klayman — 2-year suspension (SC2023-1219) — Why: Conflicts of interest suing an organization he founded and mishandling/overpublicizing a case with personal-feelings conflict and withdrawal failures.
  • Capp P. Taylor — 2-year suspension (reciprocal; nunc pro tunc) (SC2025-0664) — Why: Reciprocal Tennessee suspension and failure to notify clients/return property after prior suspension.
  • Thomas Grant Neusom — 2-year suspension (earlier) (SC2024-0611) — Why: Federal courts found procedural abuses including fabricated citations/misrepresentations and unprofessional conduct; bankruptcy sanctions for bad-faith filing.
• 1 year
  • Ryan M. Layton — 1-year suspension (SC2024-0121) — Why: Neglected multiple matters and failed to keep clients informed/diligently progress cases.
  • George Crosby Gaskell III — 1-year suspension (SC24-1527) — Why: Held in contempt for failing to comply with prior referee report/consent judgment terms and conditions.
  • Hammad Rashid Sheikh — 1-year suspension (SC25-0263) — Why: Took fees in multiple immigration cases and then failed to diligently handle them or communicate with clients.
  • Jason Alan Wiles — 1-year suspension (nunc pro tunc) (SC2025-0728) — Why: Criminal convictions including felony battery led to disciplinary suspension with required evaluation.
• 6 months
  • Jose Pete Font — 6-month suspension (SC2025-0086) — Why: Sought a contingency fee and sued the client without having a signed contingency fee agreement as required.
  • Manisha Maraj — 6-month suspension (reciprocal) (SC2024-1674) — Why: Failed to file continuance and failed to appear for sentencing; investigation found inconsistent/conflicting statements.
• 91 days
  • Najah Nzinga Adams — 91-day suspension (SC24-0241) — Why: Took fee, stopped communicating, never filed pleadings, and never responded to Bar/grievance inquiries.
  • Christopher John Atcachunas — 91-day suspension (SC24-0921) — Why: Pattern of neglect/noncommunication and misrepresented that a lawsuit had been filed when it had not.
  • Curtis Dee Mendenhall — 91-day suspension + rehab proof (SC24-1125) — Why: Made inappropriate sexual remarks to a criminal client creating a conflict, with prior similar misconduct discipline.
  • Johnny A. Pineyro — 91-day suspension + rehab proof (SC24-0913) — Why: Signed an inaccurate affidavit without adequate review, causing extra litigation and a Bar referral.
  • Danielle Renee Watson — 91-day suspension (SC2023-0416) — Why: In bad faith accused opposing counsel of forgery and escalated a correctable stipulation error.
  • Suzanne Mandich — 91-day suspension (SC2025-0515) — Why: Allowed assistant to complete parenting course for client and filed certification; failed to correct false testimony at deposition.
  • Robin E. Myers — 91-day suspension (SC2023-0999) — Why: Missed hearings, inappropriate client communications, and failed to timely respond to Bar inquiries.
  • Keith Allen Pope — 91-day suspension (reciprocal) (SC2025-0349) — Why: Reciprocal discipline after Tennessee protection-order violation and related criminal case.
  • Josh A. Howard — 91-day suspension + probation (SC2024-1261) — Why: DUI arrest and drug-related charges (later dropped via drug court) with no-contest to DUI and withhold of adjudication.
• 90 days
  • Eduardo Enrique Dieppa III — 90-day suspension (SC2024-0943) — Why: Failed to supervise a nonlawyer who made wire-transfer misrepresentations in a real estate transaction.
  • John Parker Fenner — 90-day suspension (SC2025-0001) — Why: Violated a judge’s instruction at trial, triggering mistrial and default against clients.
  • Rhonda Raulerson Portwood — 90-day suspension + Ethics School (SC24-1829) — Why: Neglect and poor supervision including filing a dissolution petition without realizing the client had died.
  • Tamara Grossman — 90-day suspension + Ethics School (SC2025-1088) — Why: Moonlighted with outside clients without firm authorization and kept files on her desktop.
  • Cheryl Culberson — 90-day suspension (SC2024-1693) — Why: Created a title cloud by seeking homestead determination for property already sold without disclosing the sale.
  • Heather Renae Marx — 90-day suspension + probation (SC2025-1075) — Why: Missed court deadlines and misrepresented to a client that she sought an extension when she had not.
• 30 days
  • Cristina Bosmenier — 30-day suspension (SC2025-0244) — Why: Prior DUI/probation history plus failure to complete a Bar diversion enhancement program, later presenting rehab/mitigation.
  • Kendrick James Blackwell — 30-day suspension + Ethics School (SC2025-1210) — Why: Violated dissolution temporary injunction by executing quitclaim deeds under POA affecting marital assets and failed to withdraw despite hotline guidance.
• 20 days
  • Wesley E. Terry — 20-day suspension (SC2024-0299) — Why: Neglected two matters, failed to communicate, and failed to respond to Bar inquiries.
  • Joan Marie Powers — 20-day suspension (SC2025-0703) — Why: Immigration representation failures (no withdrawal, missed hearing/deportation order, missed asylum deadline).
• 10 days
  • Albert V. Medina — 10-day suspension (conditions) (SC2024-1845) — Why: Misdemeanor culpable negligence causing injury after accidentally shooting his brother during horseplay.
  • Marcy S. Resnik — 10-day suspension + Ethics School (SC2025-1661) — Why: No-contest plea to resisting/obstructing without violence (summary ties to advice to a former client re police contact).

10.    Public reprimand

• Adam J. Rack — public reprimand + CLE (SC24-1130) — Why: Reciprocal Arizona discipline involving trust-funds delay/interpleader issues, conflicts, unreasonable fee provisions, and inaccurate time records.
• Harold M. Bacchus — public reprimand by publication + DDCS review (SC24-1218) — Why: Missed hearings/orders to show cause, failed to withdraw properly, and filed conclusion notice while case not concluded.
• Edwin Mills — public reprimand + DDCS + Ethics School (SC24-1239) — Why: Repeatedly failed to timely/adequately respond to Bar inquiries tied to client communication complaints.
• Dwayne D. Perser — public reprimand + office procedures review (SC24-0395) — Why: Lack of diligence and poor communication in a family case created confusion and hindered visitation coordination.
• Jeffrey Darryl Hogan — public reprimand + Trust Accounting Workshop (SC25-0154) — Why: Trust accounting record/procedure failures caused old provider payments to be missed and revealed shortages (promptly corrected).
• Shayne Jeremiah Epstein — public reprimand (published) (SC24-1739) — Why: Failed to disclose/handle a conflict where recruiting business and law practice overlapped for same client.
• Joshua Mark Silverman — public reprimand (contempt) (SC2025-0277) — Why: Failed to respond to multiple Bar inquiries and responded only after being compelled/late.
• John J. Vasti — public reprimand + Ethics School (SC2024-1295) — Why: Obstructed discovery and delayed compliance with timesharing drug-test provisions, prejudicing the other party.
• Alexis Francisco Carter, Jr. — public reprimand (published) + Professionalism Workshop (SC2024-0390) — Why: Diligence/communication failures, improper withdrawal timing, and inaccurate reporting of employment status to the Bar.
• Erika Danielle De Jesus — public reprimand (published) + Ethics/Professionalism/CLE (SC2024-1806) — Why: Conflict of interest by purchasing estate real property after witnessing the will, without proper disclosures to court/beneficiaries.
• Chantel LaVonne Grant — public reprimand (SC2024-0620) — Why: Collected fees exceeding a reasonable fee for the services provided.
• Kevin P. Mason — public reprimand (SC2025-0343) — Why: Failed to explain credit-impact risk and collected an unreasonable fee.
• Wanda Bernice Whigham — public reprimand (SC2025-1090) — Why: Late disclosure of a bank account in her personal bankruptcy case.
• Marie A. Mattox — public reprimand + DDCS (SC2025-1087) — Why: Failed to communicate with client for extended periods during post-settlement/bankruptcy claim proceedings.
• Thomas F. Rieger — public reprimand (SC2025-1273) — Why: Discovery noncompliance/handling led to sanctions issues, then dismissed case without client permission and lacked written contingency agreement.
• Scott Alan Brody — public reprimand (SC2025-1464) — Why: Practiced (demand letter) while on inactive/ineligible Florida status and failed to denote that status on website/letterhead.
• Eduardo Rodriguez — public reprimand + Ethics/Professionalism/CLE (SC2024-1273) — Why: Allowed improper notarizations (documents notarized without witnessing/signors present) as supervising partner.