section 61.16(1) need and ability to pay analysis born (Florida) · Go Syfert
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section 61.16(1) need and ability to pay analysis born in Florida

5 Florida opinions name it 1 courts 2016–2025 1 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.

Followed or applied (6)

CaseFollowedCited
Hardman v. Koslowskigreen
fladistctapp · 2013 · cited in 2 Florida opinions naming this issue, 2019–2019
2 sentences

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

22
Jones v. Jonesgreen
fladistctapp · 1996 · cited in 2 Florida opinions naming this issue, 2019–2019
2 sentences

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

22
Lori A. Ford v. Michael Withers Fordgreen
fladistctapp · 2014 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025See Ford v. Ford, 153 So. 3d 315 , 319-20 (Fla. 4th DCA 2014) (quoting Robinson-Wilson, 932 So. 2d at 331 ).

11
Robinson-Wilson v. Wilsongreen
fladistctapp · 2006 · cited in 1 Florida opinions naming this issue, 2025–2025
2 sentences

2025See Ford, 153 So. 3d at 319-20 (quoting Robinson-Wilson, 932 So. 2d at 331 ).

2025See Ford v. Ford, 153 So. 3d 315 , 319-20 (Fla. 4th DCA 2014) (quoting Robinson-Wilson, 932 So. 2d at 331 ).

11
Whittlesey v. Whittleseygreen
fladistctapp · 2008 · cited in 1 Florida opinions naming this issue, 2016–2016
1 sentence

2016See Whittlesey v. Whittlesey, 971 So.2d 1040, 1042 (Fla. 2d DCA 2008) (“Because the trial court’s determination of entitlement to fees was based on the now reversed equitable distribution scheme, the trial court’s determination of entitlement to fees must also be reversed.”). *129 Conclusion For the reasons set forth above, those aspects of the final judgment addressing the equitable distribution of the marital home and beachfront condominium and the former husband’s request for attorney’s fees are reversed.

11
Hallac v. Hallacgreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2016–2016
1 sentence

2016See Hallac v, Hallac, 88 So.3d 253, 260 (Fla. 4th DCA 2012).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Armstrong v. Armstrong green
fladistctapp · 1993
2 sentences

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

22019–2019
Worthington v. Harty green
fladistctapp · 1996
2 sentences

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

2019See Jones v. Jones , 671 So.2d 852 , 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850 in order to award attorney's fees in post-dissolution contempt proceedings); see also Hardman v. Koslowski , 107 So.3d 1246 , 1248 (Fla. 1st DCA 2013) ("Because the contempt action arose in the context of a dissolution action, the trial court was required to determine need and ability to pay before imposing this monetary sanction." (citing § 61.16(2), Fla. Stat.)); Worthington v. Harty , 677 So.2d 1371 , 1372 (Fla. 4th D

22019–2019

Statutes the citing opinions construe

FL § 61.16 (5)

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.

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