C.N. v. I.G.C.
Resolving a certified conflict among the districts, the Florida Supreme Court held that a final judgment modifying a preexisting parenting plan is not legally deficient merely because it fails to give the parent 'concrete steps' to regain lost time-sharing. The Court found no such requirement in chapter 61's text, rejected the Hunter line of district court decisions as an unanalyzed expansion from temporary visitation suspensions to final modifications, and approved the Fifth District's decision.
Key facts
- C.N. appealed a final judgment modifying a preexisting parenting plan, challenging whether the judgment was legally deficient for failing to provide concrete steps for regaining lost time-sharing.
- The trial court issued a final modification judgment that did not specify concrete steps or a pathway for the parent to restore previously held time-sharing.
- +2 more key facts with a free trial
Why it matters
This decision abrogates the long-standing district court 'concrete steps' rule (Hunter and its progeny in the Second, Third, and Fourth Districts) as applied to final modification judgments, removing a common ground for… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
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.