Baranowski v. Tesh
The Second DCA affirmed the trial court's award of lump sum durational alimony in a 26-year dissolution, holding that competent substantial evidence supported the Former Wife's need and that section 61.08(1)(a)-(b) independently authorizes lump sum payment for any form of alimony without circumventing the durational alimony modification provisions. The court reversed and remanded the child support award because the trial court failed to factor the alimony award into the child support calculation, and also reversed on ultimate decision making and the overpayment calculation based on the parties' concessions of error. The opinion is practically useful for practitioners on the proper sequencing of alimony-then-child-support calculations and the treatment of HSA contributions as medical expenses rather than investment savings.
Key facts
- Twenty-six-year marriage with one minor child; Former Wife worked part-time from 2009 to 2021 to care for the child and returned to full-time employment at UKG in 2021, earning approximately $10,640/month gross at trial versus the Former Husband's $20,998/month gross at Citigroup.
- The parties accumulated over $5 million in marital assets by the date of separation; they maintained separate accounts and a joint account to which the Former Husband contributed $5,000/month and the Former Wife contributed $2,000/month for household expenses.
- +2 more key facts with a free trial
Holdings
- A requesting spouse's need for alimony is established by competent substantial evidence where the record supports a monthly expense deficit after properly accounting for legitimate…
- +3 more holdings with a free trial
Read the full opinion, holdings & search — free for 30 days
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision — in your hands.
- Search every tracked Florida decision in seconds
- Save, tag & file the cases that matter into your own library
- Read the full plain-English analysis and holdings
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.