Mannella v. Mannella
The Sixth DCA affirmed the denial of a former husband's petition to reduce agreed-upon child support, finding competent substantial evidence that his own income had increased and that he had voluntarily restructured his employment to obtain a support reduction. In doing so, the court held that the judicially created 'heavier burden' standard for modifying support set by settlement agreement was superseded by section 61.14(7), Florida Statutes (1993), and that the Florida Supreme Court's contrary language in Overbey v. Overbey was mere obiter dictum with no precedential force. The court certified conflict with the Second, Third, and Fourth DCAs.
Key facts
- Former husband petitioned to reduce child support established by settlement agreement, claiming substantial change in circumstances based on his increased income.
- Trial court denied the petition for modification; former husband appealed to the Sixth District Court of Appeal.
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Why it matters
Beyond family law, the opinion is a useful citation for the proposition that a Florida Supreme Court statement not essential to the decision is obiter dictum lacking precedential force, and that a legislative amendment… — full analysis with a trial
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