Alonso v. De Zarraga
In a consolidated family-law appeal, the Third DCA affirmed an order determining where the parties' minor child would attend school (supported by competent substantial evidence after an evidentiary hearing), but vacated a $12,500 'sanction' imposed on the Former Wife. Because the order contained no purge provision, no coercive language, and no explanation of how the figure was calculated — and the court separately awarded the Former Husband his attorney's fees — the fine was in substance an indirect criminal contempt imposed without strict compliance with Florida Rule of Criminal Procedure 3.840.
Key facts
- Former Wife appealed a trial court order in a consolidated family-law dispute involving custody and school placement of the parties' minor child.
- The trial court determined the child's school placement after an evidentiary hearing and imposed a $12,500 monetary sanction on the Former Wife, while separately awarding the Former Husband attorney's fees for the same conduct.
- +2 more key facts with a free trial
Why it matters
A clean, citable reaffirmation that any unconditional fine lacking a purge or coercive provision is indirect criminal contempt requiring Rule 3.840 procedures — useful ammunition for reversing monetary 'sanctions'… — full analysis with a trial
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