Short v. Short
The First DCA reversed a durational alimony award because the amended final judgment, although reciting that the wife had need and the husband had the ability to pay, making section 61.08(3) findings, and computing the 35% statutory ceiling, never identified either party's reasonable expenses, quantified the wife's actual need, or determined the husband's net income after reasonable expenses. The court held those omissions violate section 61.08(2)(a)'s threshold findings requirement and remanded for the trial court to make them, without directing any particular amount.
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Key facts
- Husband and wife disputed durational alimony award in trial court, which issued amended final judgment finding need and ability to pay and applying the 35% statutory ceiling.
- Trial court's amended final judgment recited conclusory findings of need and ability to pay but failed to identify each party's reasonable expenses, quantify the wife's actual need, or determine the husband's net income after reasonable expenses.
- +2 more key facts with a free trial
Why it matters
This gives family-law counsel a clean, citable rule that the 2023 alimony statute's two-step framework requires quantified findings of reasonable expenses, actual need, and net income available after expenses — and that… — full analysis with a trial
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