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.
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