Family Law Case Updates – September, 2026

October 26, 2026
Eddie Stephens
Great law firms do more than practice law. They make a difference. The entire Eddie Stephens | Family Law team recently had the privilege of visiting Quantum House, an extraordinary organization providing a home away from home for families whose children are receiving critical medical care. We left inspired by the incredible work being done and excited about the opportunities to give back! Our team is already looking forward to getting involved—whether it's Noelle sharing her talents as a certified children's yoga instructor, Eddie delivering his Living an Extraordinary Life presentation, or all of us rolling up our sleeves to prepare a meal for 80 people! Building a new law firm is exciting. Building a culture of compassion, community, and service is what makes it meaningful. Thank you, Quantum House, for reminding us that sometimes the greatest impact we can make happens outside the courtroom. 💚 Extraordinary things happen when people come together for a greater purpose.

September marks an exciting new chapter for Stephens’ Squibs, and I have some news to share!

For more than two decades, I’ve believed that staying informed, sharing knowledge, and occasionally having a little fun with the law makes us all better attorneys. That philosophy has been the driving force behind Stephens’ Squibs since 2004.

And just like everything else in my professional life these days, we’re taking things to the next level!

I am thrilled to announce that Noelle Stone and Sarai Glaze will serve as our two editors, alternating months and bringing their own unique perspectives, talents, and personalities to the publication.

Sarai is taking the reins for this September edition, and I couldn’t be more excited about what she and Noelle will bring to the table.

Both are incredibly talented attorneys who share my passion for family law, creative thinking, and challenging conventional wisdom. They also bring fresh energy and ideas to a publication that has always been about more than simply reporting the latest cases.

After 22 years, Stephens’ Squibs isn’t slowing down. Quite the opposite.

With Noelle and Sarai helping shape its future, expect sharper analysis, fresh perspectives, some personality, and perhaps a few surprises along the way.

The law continues to evolve. So do we.

New firm. New editors. New energy. Same commitment to excellence.

Something tells me the best chapters of Stephens’ Squibs haven’t even been written yet.

Welcome aboard, Noelle and Sarai!

The best is yet to come.

Eddie Stephens, B.C.S.
Eddie Stephens | Family Law

 

 

Appeals:

Liggatt v. Liggatt, 51 Fla.L.Weekly D1856 (Fla. 6th DCA 2026).  Order granting party exclusive right to sign listing agreement to sell real property does not “determine immediate possession of property” and is there for a non-appealable non-final order.  Appeal dismissed.

Enforcement:

Neira v. Acosta, 51 Fla.L.Weekly D1765 (Fla. 3rd DCA 2026).  Purge order finding husband had current ability to pay $65,571 reversed when it did not identify source for payment.   Judge Marcia Del Rey reversed.

Del Fabbro v. Bonetto, 51 Fla.L.Weekly D1805 (Fla 3rd DCA 2026).  Trial court erred denying motion to enforce “immigration application” for child.   When provision is ambiguous, court should have taken parol and extrinsic evidence.   Judge Veronica Diaz reversed.

Modification:

Ramjas v. De La Caridad Gonzalez, 51 Fla.L.Weekly D1829 (Fla. 4TH DCA 2026).  Trial court abused its discretion finding no change of circumstances for Father who initially agreed to no timesharing because he was in medical school in New Jersey.  Now, Father is a doctor in Florida.   Although record supported 50/50 timesharing was not in child’s best interests, court abused discretion by awarding no timesharing whatsoever.   Judge Christopher Wigand affirmed in part, reversed in part.

Parenting:

Toledano v. Alvarez, 51 Fla.L.Weekly D1804 (Fla. 3rd DCA 2026).  Trial court affirmed for awarding Father nine (9) consecutive weeks of sole timesharing with minor child to reunify.  Judge Diana Vizcaino affirmed.

Partition:

Vega v. Jaramillo, 51 Fla.L.Weekly D1857 (Fla. 6th DCA 2026).  Trial court erred granting post judgment partition action on property that was deemed marital but never titled in Husband’s name.   Judge Michael Deen reversed.

Procedure:

Lisandrillo v. Palozzi, 51 Fla.L.Weekly D1922 (Fla. 4th DCA 2026).  Extraordinary writ denied and opinion written to address “AI Slop”.  Counsel’s filing contained “AI Slop” as her lengthy and unfocused filings contain gibberish and abuse legal system by churning our convoluted, false and frivolous legal pleadings.  Attorney ordered to show cause without using AI why sanctions should not be imposed.   Judge Elaine Alexandra Carbuccia Petition denied.

Unger v. Under, 51 Fla.L.Weekly D1749 (Fla. 4th DCA 2026).   Trial court improperly entered order after disqualification that contained findings of fact not orally announced before disqualification but the proper remedy is not to vacate entire order but remove findings not announced before disqualification.   Judges Jessica Marra and Elaine Alexandra Carbuccia affirmed in part, reversed in part.

Venger v. Reno, 51 Fla.L.Weekly D1735 (Fla. 1st DCA 2026).  Trial court denying motion to enforce parenting plan and motion to modify no contact order affirmed because of Tipsy Coachmen Doctrine (right result for wrong reason).  Trial court could not enforce parenting plan when dependency court entered no contact order.  Dependency order prevails pursuant to F.S. 39.013(4) and family court could not modify no contact order entered in separate dependency action.   Judge Jonathan V. Schlecter affirmed.

Farrington v. Nicolas, 51 Fla.L.Weekly D1806 (Fla. 3rd DCA 2026).   Trial court erred limiting pro se party’s “litigation behavior” without granting party notice or opportunity to be heard.   Judge Scott M. Bernstein’s order quashed.

In Re: Amendments to Florida Family Law Rules of Procedure and Rule Regulating the Florida Bar 10-2.2, 51 Fla.L.Weekly S275 (Fla. 2026).  Because the division of Florida’s family law forms have become less than ideal and a more unified and flexible approach would be more efficient all family law forms are now designated as Florida Supreme Court Approved Family Law F     orms.

Metalonis v. Metalonis, 51 Fla.L.Weekly D1895 (Fla. 3rd DCA 2026). Discovery order requiring production of all text messages between Wife and her mother, a non-party, quashed when record reflects no balancing test between need of requested information with the effected privacy interests of her Wife and Mother.   Judge George A. Sarduy’s order quashed.

Protective Injunctions:

Bernsten v. Santopietro, 51 Fla.L.Weekly D1945 (Fla. 6th DCA 2026).  Stalking injunction reversed when only based on rude comments and spreading false narratives.   Judge John S. Carlin reversed.

Keller v. Keller, 51 Fla.L.Weekly D1909 (Fla. 3rd DCA 2026).  Order denying motion to dissolve injunction because Respondent is incarcerated affirmed.   Injunction protected petitioner from contact and respondent is able to send correspondence from jail.   Judge James W. Morgan affirmed.

Duby v. Marrero, 51 Fla.L.Weekly D1750 (Fla. 4th DCA 2026).  Stalking injunction affirmed.   Strong dissent by Justice Frost that respondent was denied due process when his motion to appear by zoom because he could not afford transportation was denied.   Judge Machael David Porter affirmed.

Support:

Swift v.Poitras, 51 Fla.L.Weekly D1905 (Fla. 6th DCA 2026).  Trial court erred by deducting $193,000 for 2020 tax payments and $481,000 for 2019 tax payments in the absence of competent, substantial evidence  to support these deductions from income.   Trial court should not have calculated overnights for Father in determining retroactive support for nights he was visiting the  children at Mother’s house where did not pay rent.   Trial court also failed to address retroactive nanny and day care costs.   Judge Ramiro Mañalich affirmed in part, reversed in part.

Categories