Golliner v. Golliner
The Second District reversed a dissolution judgment that awarded the wife only two years of bridge-the-gap alimony after a twelve-year marriage, holding that the trial court's findings—including that her PTSD and depression 'would subside' and that she was using the domestic violence incident as a 'crutch'—were unsupported by competent substantial evidence and identified no 'legitimate identifiable short-term need' under section 61.08(6). The court also reversed the child support calculation, which was based solely on the husband's lowest-year financial affidavit despite a higher tax return for the same year and years of prelitigation income history, and reversed the summary denial of attorney's fees after the court had promised a separate hearing.
Key facts
- Wife and Husband divorced after a twelve-year marriage; the trial court awarded Wife only two years of bridge-the-gap alimony and calculated Child Support based on Husband's lowest financial affidavit despite higher tax return documentation.
- The trial court found Wife's PTSD and depression 'would subside' and she was using domestic violence as a 'crutch,' and summarily denied Attorney's Fees without the promised separate hearing.
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Why it matters
A useful decision for family practitioners policing the line between bridge-the-gap and rehabilitative/durational alimony: the court holds that a payee's need for retraining and reentry into the workforce is not an… — full analysis with a trial
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