Beans v. Beans
The First DCA affirmed an order modifying (reducing) permanent alimony, rejecting the former husband's arguments that were premised on section 61.08 (the original-award alimony statute). The majority held that modification proceedings are governed exclusively by section 61.14, that section 61.08's mandatory factors and net-income limitation do not apply on modification, and that prior decisions to the contrary (Schang, Galligar) were superseded by the 2010 statutory cross-reference amendments. It affirmed under the right-result/wrong-reason doctrine even though no party had cited section 61.14 below or on appeal; Judge Kelsey dissented on preservation and en banc-recession grounds.
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