Garcia v. Garcia
After a thirteen-day dissolution trial, the trial court found the wife had no need for fees but awarded her $50,000 based on the husband's bad-faith litigation conduct dash concealing a notebook of rental income/expense records until mid-trial despite extensive discovery litigation. The Fifth DCA affirmed equitable distribution and the wife's entitlement to a bad-faith fee award under Rosen v. Rosen, but reversed the $50,000 amount because the trial judge made no findings supporting the calculation.
Key facts
- Husband and wife disputed dissolution of marriage after thirteen-day trial in which trial court found wife had no financial need for attorney's fees.
- Wife sought attorney's fees based on husband's bad-faith conduct in concealing notebook containing rental income and expense records until mid-trial despite extensive discovery litigation and motions to compel.
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Why it matters
This decision gives family and civil practitioners a clean, citable statement that Rosen bad-faith fees are available notwithstanding a finding of no need dash useful both offensively against discovery stonewalling and… — full analysis with a trial
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