Ramjas v. Gonzalez
A father whose original paternity judgment gave the mother sole parental responsibility and sole timesharing petitioned to modify after completing an out-of-state medical residency and moving to Fort Lauderdale. The Fourth District held the trial court abused its discretion in finding no substantial and material change: under section 61.13(3), the father's uncontroverted testimony established he resided in New Jersey when the last timesharing order was entered and his move to within 50 miles of the mother, combined with a drastically reduced work schedule, was a substantial change. The court affirmed denial of equal timesharing and shared parental responsibility, but reversed the complete denial of any contact and directed the trial court to craft graduated (telephonic/supervised to unsupervised) timesharing.
Key facts
- Father petitioned to modify a paternity judgment that originally awarded mother sole parental responsibility and sole timesharing after he completed an out-of-state medical residency and relocated to Fort Lauderdale.
- Trial court found no substantial and material change in circumstances warranting modification and denied father any timesharing or contact with the child.
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Why it matters
This is one of the first appellate decisions applying the 2023 amendments to section 61.13(3) — both the deletion of the 'unanticipated' requirement and the 50-mile relocation provision — and it clarifies that the… — full analysis with a trial
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