Florida’s divorce statutes change every few years; the case law applying them to alimony, property, businesses and support changes every week. This page lists, newest first and sorted by issue, every recent Florida appellate decision that affects the financial side of a divorce — with a plain-English note on what each one means for how a case should be tried, settled or drafted. Written by the attorney. Updated weekly; last rebuilt October 31, 2026.
How this page stays current
A proprietary case-law monitoring system, run every week
Mack Law P.A. runs a proprietary review system that screens every newly released Florida appellate opinion — the Florida Supreme Court and all six district courts of appeal — for anything that changes how money is handled in a divorce: alimony, equitable distribution, business and professional-practice valuation, imputed income, child-support arithmetic, attorney’s fees, and the enforcement of all of it. Each qualifying decision is summarized here in plain English and, more importantly, folded into how we try, settle and draft our cases. The page is rebuilt every week; the newest rulings appear first and older ones move to the quarterly archive automatically.
Browse by issue
Latest rulings
- Malone v. MaloneOctober 30, 2026 · Business & titling
- Short v. ShortOctober 28, 2026 · Alimony
- Alvarez v. CuetoOctober 28, 2026 · Enforcement
- Garcia v. GarciaOctober 23, 2026 · Attorney’s fees
- Ali v. ShoukatOctober 16, 2026 · Alimony
- Molo v. MoloOctober 9, 2026 · Child support
No ruling on this page matches that search. Try a broader word, or check the quarterly archive below.
Alimony 5 rulings
Need, ability to pay, the 35% cap, bridge-the-gap and durational awards, and what the judgment must say.
-
October 28, 2026 · First District Court of Appeal
Short v. Short
No. 1D2025-0918 (Fla. 1st DCA Oct. 28, 2026) · Reversed in part
What the court held. An alimony award needs specific findings of the recipient's actual need and the payor's actual ability to pay, measured on net income after reasonable expenses. Reciting the statutory factors and computing the 35%-of-net-difference cap is not enough, and the appellate court will not infer need from the size of the award.
Why it matters. The judgment has to show the arithmetic. We build a net-income exhibit for each spouse — gross, deductions, reasonable expenses, the remainder — so the findings the First District demands are already on the record.
Affects: Alimonyneed and ability35% capfindings
-
October 16, 2026 · Fifth District Court of Appeal
Ali v. Shoukat
No. 5D2025-1410 (Fla. 5th DCA Oct. 16, 2026) · Reversed in part
What the court held. After a 249-day marriage, the trial court awarded nine months of bridge-the-gap alimony at $2,675.87 a month, borrowing the duration from reported cases because the wife only testified she could not support herself for “several months.” Reversed: bridge-the-gap requires proof of the specific short-term needs and how long they will last.
Why it matters. In a short marriage the alimony case is won or lost on specifics — the lease that ends in March, the certification that takes six months. Vague testimony produces no award at all.
Affects: Bridge-the-gap alimonybridge-the-gapshort marriageduration
-
August 19, 2026 · Fourth District Court of Appeal
Gonzalez v. Gonzalez
No. 4D2025-2461 (Fla. 4th DCA Aug. 19, 2026) · Reversed in part
What the court held. A 2013 agreement said alimony would continue “until [the wife] is remarried.” When the former husband retired and sought to reduce it, the trial court held the agreement had waived modification. Reversed: the statutory right to modify alimony under section 61.14 is read into every agreement unless the waiver is express or unmistakable, and naming one terminating event is not a waiver.
Why it matters. If alimony is meant to be untouchable, the agreement must say “nonmodifiable” in those words. Every alimony clause we draft states whether it can be modified and when.
Affects: Modificationalimony modificationretirementwaiver
-
July 22, 2026 · Second District Court of Appeal
Baranowski v. Tesh
No. 2D2024-1967 (Fla. 2d DCA July 22, 2026) · Affirmed in part
What the court held. After a twenty-six-year marriage with more than five million dollars in assets, the court ordered durational alimony paid as a lump sum. The Second District held that a lump-sum form needs no finding of “special circumstances,” that a spouse's HSA contributions used for the family deductible are not speculative savings, and that child expenses on a financial affidavit are not double-counted unless they also appear in the child-support worksheet.
Why it matters. Lump-sum alimony is a legitimate tool for high-asset cases where a clean break is worth more than a monthly check. The financial affidavit has to be built to survive this kind of line-by-line audit.
Affects: Durational alimonylump-sum alimonyfinancial affidavithigh-asset
-
July 15, 2026 · Fourth District Court of Appeal
O’Donnell v. O’Donnell
No. 4D2025-0004 (Fla. 4th DCA July 15, 2026) · Reversed in part
What the court held. The final judgment omitted the alimony duration the parties had agreed to, decided a life-insurance issue the court had reserved for a later hearing, and skipped the income deduction order. Meanwhile the former husband deducted boat-repair costs from his alimony payments. Reversed on each point: the judgment must state the form and duration of alimony, an income deduction order is mandatory, and a payor may not help himself to offsets against court-ordered support.
Why it matters. Self-help against support is contempt in waiting. Payors who think they are owed money need a motion, not a deduction; recipients should insist on the income deduction order the statute requires.
Affects: Alimonyincome deduction orderself-helpalimony duration
Equitable distribution 1 ruling
How the marital estate is valued, divided and — when a case drags — charged with interest.
-
July 9, 2026 · Florida Supreme Court
Stewart v. Perdomo Vindel
No. SC2024-0428 (Fla. July 9, 2026) · Affirmed
What the court held. In a divorce that took years to resolve, the trial court valued the marital estate as of the filing date and refused the former wife interest on her share for the delay. The Florida Supreme Court settled a conflict among the districts: a trial court may award prejudgment interest as part of equitable distribution under section 61.075(1). It is discretionary, not automatic, and the record must support it — for example, one spouse's exclusive use of marital assets while the case dragged on.
Why it matters. Delay now has a price. The spouse who controls the assets during a long case can be charged interest on the other spouse's share, which changes the economics of stalling.
Affects: Property divisionprejudgment interestvaluation dateFlorida Supreme Court
Businesses, real estate & how assets are titled 3 rulings
Closely held companies, partner debt, deeds, leases and the ownership forms that decide who gets what.
-
October 30, 2026 · Fifth District Court of Appeal
Malone v. Malone
No. 5D2025-0653 (Fla. 5th DCA Oct. 30, 2026) · Reversed in part
What the court held. The trial court charged the husband with 100% of a business's debt even though the couple owned only 51% of the company and a partner was responsible for the rest. The Fifth District reversed — and because moving one debt changes the balance of everything else, it sent the entire equitable distribution back to be redone.
Why it matters. Ownership percentages and third-party liability have to be proven at trial, not assumed. We put the cap table, the operating agreement and the partner's share of every liability into the business schedule before the first hearing.
Affects: Valuing a business in divorcebusiness debtequitable distribution
-
September 9, 2026 · First District Court of Appeal
Shannon v. Wang
No. 1D2025-1444 (Fla. 1st DCA Sept. 9, 2026) · Reversed in part
What the court held. Spouses who ran hotels and restaurants together signed a sixty-year ground lease as “Husband and Wife,” with the rent deposited into a joint account; title to the land was in the husband's name alone. After his death the question was whether the rent stream passed to the widow by survivorship. The First District held that whether spouses created a tenancy by the entireties is a question of fact, and a lease that says nothing about survivorship does not settle it.
Why it matters. How an asset is titled decides who owns it, in divorce and at death. For business-owning couples we audit every deed, lease and account for its ownership form before anyone argues about value.
Affects: High-net-worth divorcetenancy by the entiretiestitlingcommercial lease
-
September 4, 2026 · Sixth District Court of Appeal
Vega v. Jaramillo
No. 6D2025-0532 (Fla. 6th DCA Sept. 4, 2026) · Reversed
What the court held. The dissolution judgment called the home “marital,” gave the husband possession and the $391,692 mortgage, and ordered no equalizing payment; the deed had always been in his name alone. The former wife then sued to partition the house and won below. The Sixth District reversed: labeling a home marital for distribution purposes transfers no title, so a spouse who is not on the deed has no standing to partition.
Why it matters. A judgment that does not expressly transfer title or order an equalizer leaves the non-titled spouse with nothing to enforce. We draft the property paragraphs of every judgment as if a title company will read them, because one will.
Affects: Property divisionmarital hometitlepartition
Income, imputation & financial disclosure 2 rulings
What counts as income, when a court may impute it, and how far financial privacy stretches once income is in issue.
-
August 26, 2026 · Third District Court of Appeal
Law Offices of Adorno-Cunill & Damas v. Dylewski
No. 3D2026-0840 (Fla. 3d DCA Aug. 26, 2026) · Order quashed
What the court held. A physician sued his former divorce lawyers, claiming they let him agree to $18,500 a month in alimony on a $950,000 income figure he said was temporarily inflated. When the firm sought his later tax returns and income records to test that claim, the trial court refused. The Third District quashed that ruling: a party who puts his own income history in issue cannot shield the records that would prove or disprove it.
Why it matters. Financial privacy yields to relevance. The income figures in a settlement or a judgment are facts that will be tested years later, so they have to be right — and footnoted — when they are made.
Affects: Physician divorceincome recordsfinancial privacydiscovery
-
August 14, 2026 · Second District Court of Appeal
Huffman v. Huffman
No. 2D2025-0372 (Fla. 2d DCA Aug. 14, 2026) · Reversed in part
What the court held. The trial court found the husband earned $130,000 gross with $5,600 net a month, imputed $3,500 a month to the wife as a pharmacy technician, and awarded $1,700 in durational alimony. Reversed: a judgment that states a net income figure without identifying the expenses deducted cannot be reviewed for ability to pay, and imputation requires particularized findings on work history, qualifications and the local job market that the evidence actually supports.
Why it matters. Imputed income is where alimony and child-support cases are most often won and lost. We bring the vocational evidence and the local job-market data, and we insist the judgment show its work.
Affects: Imputation of incomeimputed incomenet incomedurational alimony
Child support — the money side 1 ruling
Guideline arithmetic, how alimony feeds into it, and the limits of a payor’s ability to pay.
-
October 9, 2026 · Fifth District Court of Appeal
Molo v. Molo
No. 5D2024-1908 (Fla. 5th DCA Oct. 9, 2026) · Reversed in part
What the court held. The trial court imputed $55,000 a year plus rental income to the husband, awarded durational alimony and set child support — but left the alimony out of the wife's income when it ran the child-support guidelines. Reversed: alimony ordered in the same case counts as the recipient's income under section 61.30(2)(a)9., the alimony findings must cover every relevant factor, and support cannot exceed what the payor can actually pay after the court's own orders.
Why it matters. Alimony and child support are one calculation, not two. We run both worksheets together so the numbers reconcile and the payor is not ordered to pay more than exists.
Affects: Child supportguidelinesimputed incomealimony as income
Attorney’s fees & costs 3 rulings
Need-based fees, temporary fees, and fees as a sanction for hiding the ball.
-
October 23, 2026 · Fifth District Court of Appeal
Garcia v. Garcia
No. 5D2024-2992 (Fla. 5th DCA Oct. 23, 2026) · Reversed in part
What the court held. After a thirteen-day trial, the husband was ordered to pay $50,000 of the wife's fees — not because she needed help, but because he withheld a notebook of rental income and expense records until the middle of trial. The Fifth District agreed that bad-faith litigation conduct supports a fee award even without need, but reversed the amount because the judge never explained the rate, the hours, or how much of the fee the misconduct caused.
Why it matters. Hiding financial records is a money decision with a price tag. For the spouse on the receiving end, document every discovery request and every delay; the fee award follows the paper trail.
Affects: High-net-worth divorcebad-faith feesrental incomediscovery
-
August 14, 2026 · Second District Court of Appeal
Williams v. Williams
No. 2D2025-1777 (Fla. 2d DCA Aug. 14, 2026) · Reversed in part
What the court held. A $75,000 temporary attorney's-fee award was reversed as to amount. Need and ability to pay establish entitlement, but the order must also find that the hourly rate and the hours claimed are reasonable; this one set the figure with no such findings.
Why it matters. Temporary fees fund the case for the spouse with less access to money, and they are vulnerable on appeal unless the billing record is in evidence. We put rate, hours and task detail in front of the judge at the temporary-relief hearing.
Affects: Contested divorcetemporary feesreasonableness findings
-
July 22, 2026 · Third District Court of Appeal
Da Silva v. Labriola
No. 3D2024-2039 (Fla. 3d DCA July 22, 2026) · Reversed in part
What the court held. After a multi-day trial with competing medical, accounting and vocational experts, the court denied alimony because the wife could work but chose not to, then found her entitled to fees without a hearing. The Third District held that fee entitlement under section 61.16 requires an evidentiary hearing absent a stipulation, and that a court denying alimony for lack of need only has to make the need-and-ability findings, not findings on every factor.
Why it matters. Fee entitlement is its own mini-trial. Both sides should expect to prove — or contest — need and ability with evidence, not argument.
Affects: Alimonyattorney's feesevidentiary hearingalimony denied
Enforcement, contempt & collection 4 rulings
Garnishment, contempt, forced sales and the findings an enforcement order must contain.
-
October 28, 2026 · Third District Court of Appeal
Alvarez v. Cueto
No. 3D2024-2310 (Fla. 3d DCA Oct. 28, 2026) · Affirmed in part
What the court held. A judgment ordered four marital properties and an assisted-living business sold with the proceeds split. Years later the mortgage went unpaid and foreclosure loomed. The trial court, which had reserved jurisdiction, could compel an immediate sale to head off the foreclosure; a fee ruling that decided entitlement but not amount was not yet appealable.
Why it matters. Once a court orders a sale, dragging your feet invites a forced sale on the court's terms, not yours. If you want to keep a property, the buyout has to be funded on the judgment's timetable.
Affects: Enforcement of judgmentsforced saleforeclosureattorney's fees
-
October 7, 2026 · Fourth District Court of Appeal
Kennedy v. Kennedy
No. 4D2025-2845 (Fla. 4th DCA Oct. 7, 2026) · Affirmed
What the court held. A 2003 judgment incorporated the couple's agreement for nonmodifiable alimony. When the former husband fell behind while living on disability income, he argued federal law capped garnishment at 25%. The Fourth District disagreed: alimony under an agreement incorporated into a judgment is a court order for support, so withholding of up to 50–65% of wages or Social Security is allowed.
Why it matters. Agreed alimony collects like any court order, and retirement income is not a shelter. Payors need a modification strategy before the arrears build; recipients have more collection power than they usually think.
Affects: Enforcement of judgmentsgarnishmentSocial Securitynonmodifiable alimony
-
October 7, 2026 · Fourth District Court of Appeal
Azulay v. Azulay
No. 4D2025-2197 (Fla. 4th DCA Oct. 7, 2026) · Reversed in part
What the court held. The husband was held in contempt for living in the marital home and “sabotaging” its court-ordered sale, and a real-estate attorney was appointed to sell it at his expense. While that appeal was pending, the Fourth District reversed the forced-sale provision itself — so the contempt order and the agent's fees fell with it. A reservation of jurisdiction for attorney's fees survived.
Why it matters. When the sale order is on appeal, the enforcement calculus changes for both sides. We stage enforcement motions against the appellate calendar instead of racing it.
Affects: Property divisionmarital homecontemptforced sale
-
August 26, 2026 · Third District Court of Appeal
Fuentes Neira v. Cardona Acosta
No. 3D2025-1736 (Fla. 3d DCA Aug. 26, 2026) · Reversed
What the court held. A husband found to earn at least $24,023 net a month was ordered to pay $9,000 in temporary support plus child support and arrears, then jailed for civil contempt with a $65,115 purge. Reversed: an order that jails a contemnor must make a separate, evidence-based finding of present ability to pay the purge from his own identified assets — not a relative's, and not an inference from gaps in his paperwork.
Why it matters. Contempt is the most powerful collection tool in family court and the easiest to lose on appeal. We prove the source of funds for the purge before we ask for incarceration.
Affects: Enforcement of judgmentscivil contemptpurgetemporary support
Settlement agreements 1 ruling
How courts read the words the parties chose — and what happens when a clause has a gap.
-
September 23, 2026 · Fourth District Court of Appeal
Valiente v. Romero
No. 4D2025-1919 (Fla. 4th DCA Sept. 23, 2026) · Reversed
What the court held. The settlement agreement let one spouse keep the house by paying $140,000 within 60 days; otherwise it would be sold and the net proceeds split equally. The buyout never happened, the house sold with about $186,000 in net proceeds, and the trial court still awarded the fixed $140,000. Reversed: the two clauses were separate alternatives, and every sentence of an agreement must be given effect.
Why it matters. Buyout and fallback clauses need to say exactly when each applies and what happens if the numbers move. We write property terms as if–then sequences with no gap between them.
Affects: Property divisionbuyout clausesettlement agreementmarital home
Trial practice & appeals in financial cases 2 rulings
Transcripts, time limits, amended judgments and the deadlines that decide whether a money ruling can be reviewed.
-
October 7, 2026 · Third District Court of Appeal
Giroux v. Giroux
No. 3D2025-0648 (Fla. 3d DCA Oct. 7, 2026) · Affirmed in part
What the court held. After a seven-day trial the court corrected a bank-account value from $11,177 to $101,177 and added a $491,291 equalizing payment in an amended judgment. The Third District held that an amendment changing substantive rights restarts the appeal clock, but only the amended parts can be reviewed — and without a trial transcript, the alimony, fee and distribution findings could not be attacked at all.
Why it matters. In a financial case the transcript is not optional. We order it as a matter of course, and we calendar the rehearing and appeal deadlines from the amended judgment, not the original.
Affects: Property divisionequalizing paymentamended judgmenttranscript
-
September 30, 2026 · Fourth District Court of Appeal
Baron v. Baron
No. 4D2025-2359 (Fla. 4th DCA Sept. 30, 2026) · Affirmed
What the court held. The former wife asked for five trial days and was given one, announced in advance. No due-process violation: a party is entitled to a fair share of the court's time and a real chance to present the case, not unlimited time — and she never showed what witness or exhibit the limit kept out.
Why it matters. Complex financial cases are increasingly tried on a clock. We build the exhibit book and witness order to fit the day we are given, and we proffer on the record anything the clock cuts off.
Affects: Contested divorcetrial time limitsdue process
How to read these entries
Each entry gives the court, the decision date, the docket number and the outcome, then two short paragraphs: what the court held, and why it matters for someone going through a divorce in Florida. Entries are grouped by the financial issue they decide and listed newest first; the five most recent in each group are open and the rest sit under “Earlier rulings.” Citations are to the slip opinions as released. A later opinion on rehearing, a Florida Supreme Court decision or a statutory amendment can change the law described here, and no summary substitutes for reading the opinion or for advice on your own facts.
Facing a divorce where the money is the fight?
Complex and high-net-worth divorce, business owners, physicians and professionals — tried and settled by the attorney who reads these opinions the week they come out. Call (407) 749-1034 or request a confidential consultation.
General information about Florida law — not legal advice, and no attorney-client relationship is created by reading it. This page summarizes published Florida appellate opinions for general information; it is attorney advertising. Last updated October 31, 2026.