Rosi Gaul v. Jeffrey Gaul
The Sixth DCA aligned with the First, Fourth, and Fifth Districts and held that a dissolution petition is 'pending' under § 61.08(11) only until the trial court renders final judgment—not through the completion of any appellate proceedings. Because the final judgment was entered December 28, 2020 (before the July 1, 2023 statutory amendment), the 2023 version of § 61.08 does not apply and the trial court's permanent alimony award stands. The court certified direct conflict with the Second District.
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