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6 Florida opinions name it 1 courts 1997–2025 3 in the last five years
The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Rhonda Hines v. Arthur Williamsgreen1 sentence2025See Badgley, 165 So. 3d at 744–45 (reversing and remanding for required factual findings under section 61.08); Rowe-Lewis v. Lewis, 267 So. 3d 1039, 1042 (Fla. 4th DCA 2019) (reversing and remanding for evidentiary hearing and entry of final judgment that includes findings of fact and consideration of each section 61.08 factor for determining alimony); see also Hines v. Williams, 384 So. 3d 237 , 240 (Fla. 4th DCA 2024) (“[G]iven the passage of time . . . and the lack of transcripts from those hearings, the circuit court, in its discretion, may: (1) take additional evidence and conduct further | 1 | 1 |
Ondrejack v. Ondrejackgreen1 sentence2025Badgley v. Sanchez, 165 So. 3d 742 , 744–45 (Fla. 4th DCA 2015) (reversing alimony award because, even in the absence of a transcript, the trial court 3 erred in failing to make the findings required in section 61.08); Ondrejack, 839 So. 2d at 870 (holding the failure to consider all of the mandated factors of section 61.08 reversible error); Jocelyn v. Jocelyn, 392 So. 3d 169 , 170 (Fla. 5th DCA 2024) (reversing final judgment for failure to make required findings to support alimony award despite a lack of transcript because errors were apparent from face of the judgment). | 1 | 1 |
THELMA ROWE-LEWIS v. HORACE LEWISgreen1 sentence2025See Badgley, 165 So. 3d at 744–45 (reversing and remanding for required factual findings under section 61.08); Rowe-Lewis v. Lewis, 267 So. 3d 1039, 1042 (Fla. 4th DCA 2019) (reversing and remanding for evidentiary hearing and entry of final judgment that includes findings of fact and consideration of each section 61.08 factor for determining alimony); see also Hines v. Williams, 384 So. 3d 237 , 240 (Fla. 4th DCA 2024) (“[G]iven the passage of time . . . and the lack of transcripts from those hearings, the circuit court, in its discretion, may: (1) take additional evidence and conduct further | 1 | 1 |
Costa v. Costagreen1 sentence2025See Addie, 120 So. 3d at 46 (citing Costa, 951 So. 2d at 925 ). 3 While section 61.08 requires specific factual findings regarding the factors listed in subsection (2), an exception exists where the parties have entered into a valid agreement regarding spousal support on the record. | 1 | 1 |
Robert N. Badgley, Jr. v. Maria Belen Sanchezgreen2 sentences2025Badgley v. Sanchez, 165 So. 3d 742 , 744–45 (Fla. 4th DCA 2015) (reversing alimony award because, even in the absence of a transcript, the trial court 3 erred in failing to make the findings required in section 61.08); Ondrejack, 839 So. 2d at 870 (holding the failure to consider all of the mandated factors of section 61.08 reversible error); Jocelyn v. Jocelyn, 392 So. 3d 169 , 170 (Fla. 5th DCA 2024) (reversing final judgment for failure to make required findings to support alimony award despite a lack of transcript because errors were apparent from face of the judgment). 2025See Badgley, 165 So. 3d at 744–45 (reversing and remanding for required factual findings under section 61.08); Rowe-Lewis v. Lewis, 267 So. 3d 1039, 1042 (Fla. 4th DCA 2019) (reversing and remanding for evidentiary hearing and entry of final judgment that includes findings of fact and consideration of each section 61.08 factor for determining alimony); see also Hines v. Williams, 384 So. 3d 237 , 240 (Fla. 4th DCA 2024) (“[G]iven the passage of time . . . and the lack of transcripts from those hearings, the circuit court, in its discretion, may: (1) take additional evidence and conduct further | 1 | 1 |
Addie v. Coalegreen1 sentence2025See Addie, 120 So. 3d at 46 (citing Costa, 951 So. 2d at 925 ). 3 While section 61.08 requires specific factual findings regarding the factors listed in subsection (2), an exception exists where the parties have entered into a valid agreement regarding spousal support on the record. | 1 | 1 |
MARCIA STIVELMAN v. JACQUES CLAUDIO STIVELMANgreen1 sentence2025See Stivelman v. Stivelman, 355 So. 3d 1021 (Fla. 3d DCA 2023). | 1 | 1 |
Roth v. Cortinagreen1 sentence2014See Roth v. Cortina, 59 So.3d 163, 165-66 (Fla. 3d DCA 2011). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Samuel Jocelyn v. Peggy Esmerelda Jocelyn
neutral
1 sentence2025Badgley v. Sanchez, 165 So. 3d 742 , 744–45 (Fla. 4th DCA 2015) (reversing alimony award because, even in the absence of a transcript, the trial court 3 erred in failing to make the findings required in section 61.08); Ondrejack, 839 So. 2d at 870 (holding the failure to consider all of the mandated factors of section 61.08 reversible error); Jocelyn v. Jocelyn, 392 So. 3d 169 , 170 (Fla. 5th DCA 2024) (reversing final judgment for failure to make required findings to support alimony award despite a lack of transcript because errors were apparent from face of the judgment). | 1 | 2025–2025 |
Chovan v. Chovan
green
1 sentence2025Chovan v. Chovan, 90 So. 3d 898 , 901 n.1 (Fla. 4th DCA 2012). | 1 | 2025–2025 |
Brezault v. Brezault
green
1 sentence2019Id. at 523 . | 1 | 2019–2019 |
Harreld v. Harreld
green
1 sentence1997The husband correctly points out that the court must make the required findings under section 61.08(2). § 61.08(1), Fla.Stat. (1993); Harreld v. Harreld, 682 So.2d 635 (Fla. 2d DCA 1996). | 1 | 1997–1997 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.