Florida Statutes

Fla. Stat. § 61.075 (2025)

Equitable distribution of marital assets and liabilities.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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61.075 Equitable distribution of marital assets and liabilities.—

(1) In a proceeding for dissolution of marriage, in addition to all other remedies available to a court to do equity between the parties, or in a proceeding for disposition of assets following a dissolution of marriage by a court which lacked jurisdiction over the absent spouse or lacked jurisdiction to dispose of the assets, the court shall set apart to each spouse that spouse’s nonmarital assets and liabilities, and in distributing the marital assets and liabilities between the parties, the court must begin with the premise that the distribution should be equal, unless there is a justification for an unequal distribution based on all relevant factors, including:

(a) The contribution to the marriage by each spouse, including contributions to the care and education of the children and services as homemaker.

(b) The economic circumstances of the parties.

(d) Any interruption of personal careers or educational opportunities of either party.

(e) The contribution of one spouse to the personal career or educational opportunity of the other spouse.

(f) The desirability of retaining any asset, including an interest in a business, corporation, or professional practice, intact and free from any claim or interference by the other party.

(g) The contribution of each spouse to the acquisition, enhancement, and production of income or the improvement of, or the incurring of liabilities to, both the marital assets and the nonmarital assets of the parties.

(h) The desirability of retaining the marital home as a residence for any dependent child of the marriage, or any other party, when it would be equitable to do so, it is in the best interest of the child or that party, and it is financially feasible for the parties to maintain the residence until the child is emancipated or until exclusive possession is otherwise terminated by a court of competent jurisdiction. In making this determination, the court shall first determine if it would be in the best interest of the dependent child to remain in the marital home; and, if not, whether other equities would be served by giving any other party exclusive use and possession of the marital home.

(i) The intentional dissipation, waste, depletion, or destruction of marital assets after the filing of the petition or within 2 years prior to the filing of the petition.

(j) Any other factors necessary to do equity and justice between the parties.

(2) If the court awards a cash payment for the purpose of equitable distribution of marital assets, to be paid in full or in installments, the full amount ordered shall vest when the judgment is awarded and the award shall not terminate upon remarriage or death of either party, unless otherwise agreed to by the parties, but shall be treated as a debt owed from the obligor or the obligor’s estate to the obligee or the obligee’s estate, unless otherwise agreed to by the parties.

(3) In any contested dissolution action wherein a stipulation and agreement has not been entered and filed, any distribution of marital assets or marital liabilities shall be supported by factual findings in the judgment or order based on competent substantial evidence with reference to the factors enumerated in subsection (1). The distribution of all marital assets and marital liabilities, whether equal or unequal, shall include specific written findings of fact as to the following:

(a) Clear identification of nonmarital assets and ownership interests;

(b) Identification of marital assets, including the individual valuation of significant assets, and designation of which spouse shall be entitled to each asset;

(d) Any other findings necessary to advise the parties or the reviewing court of the trial court’s rationale for the distribution of marital assets and allocation of liabilities.

(4) The judgment distributing assets shall have the effect of a duly executed instrument of conveyance, transfer, release, or acquisition which is recorded in the county where the property is located when the judgment, or a certified copy of the judgment, is recorded in the official records of the county in which the property is located.

(5) If the court finds good cause that there should be an interim partial distribution during the pendency of a dissolution action, the court may enter an interim order that shall identify and value the marital and nonmarital assets and liabilities made the subject of the sworn motion, set apart those nonmarital assets and liabilities, and provide for a partial distribution of those marital assets and liabilities. An interim order may be entered at any time after the date the dissolution of marriage is filed and served and before the final distribution of marital and nonmarital assets and marital and nonmarital liabilities.

(a) Such an interim order shall be entered only upon good cause shown and upon sworn motion establishing specific factual basis for the motion. The motion may be filed by either party and shall demonstrate good cause why the matter should not be deferred until the final hearing.

(b) The court shall specifically take into account and give appropriate credit for any partial distribution of marital assets or liabilities in its final allocation of marital assets or liabilities. Further, the court shall make specific findings in any interim order under this section that any partial distribution will not cause inequity or prejudice to either party as to either party’s claims for support or attorney’s fees.

(c) Any interim order partially distributing marital assets or liabilities as provided in this subsection shall be pursuant to and comport with the factors in subsections (1) and (3) as such factors pertain to the assets or liabilities made the subject of the sworn motion.

(d) As used in this subsection, the term “good cause” means extraordinary circumstances that justify an interim partial distribution. In determining if extraordinary circumstances exist for purposes of this subsection, the court must consider the following:

1. Whether there is a need for funds in order to avoid or prevent the loss of an asset through repossession or foreclosure, the loss of housing, the default by either party of a marital debt, or the levy of a tax lien.

2. Whether there is a need for funds to pay an expense for a dependent child if nonpayment of the expense would be detrimental to the child.

3. Whether one or both parties have a need to access funds in order to pay a reasonable amount of the attorney fees, court costs, or other suit money for maintaining or defending a proceeding under this chapter.

4. Any other circumstances that justify the entry of an order granting an interim partial equitable distribution.

(6) As used in this section:

(a)1. “Marital assets and liabilities” include all of the following:

a. Assets acquired and liabilities incurred during the marriage, individually by either spouse or jointly by them.

b. The enhancement in value and appreciation of nonmarital assets resulting from the efforts of either party during the marriage or from the contribution to or expenditure thereon of marital funds or other forms of marital assets, or both.

c. The paydown of principal of a note and mortgage secured by nonmarital real property and a portion of any passive appreciation in the property, if the note and mortgage secured by the property are paid down from marital funds during the marriage. The portion of passive appreciation in the property characterized as marital and subject to equitable distribution is determined by multiplying a coverture fraction by the passive appreciation in the property during the marriage.

(I) The passive appreciation is determined by subtracting the value of the property on the date of the marriage or the date of acquisition of the property, whichever is later, from the value of the property on the valuation date in the dissolution action, less any active appreciation of the property during the marriage as described in sub-subparagraph b., and less any additional encumbrances secured by the property during the marriage in excess of the first note and mortgage on which principal is paid from marital funds.

(II) The coverture fraction must consist of a numerator, defined as the total payment of principal from marital funds of all notes and mortgages secured by the property during the marriage, and a denominator, defined as the value of the subject real property on the date of the marriage, the date of acquisition of the property, or the date the property was encumbered by the first note and mortgage on which principal was paid from marital funds, whichever is later.

(III) The passive appreciation must be multiplied by the coverture fraction to determine the marital portion of the passive appreciation of the property.

(IV) The total marital portion of the property consists of the marital portion of the passive appreciation, the mortgage principal paid during the marriage from marital funds, and any active appreciation of the property during the marriage as described in sub-subparagraph b., not to exceed the total net equity in the property at the date of valuation.

(V) The court shall apply the formula specified in this subparagraph unless a party shows circumstances sufficient to establish that application of the formula would be inequitable under the facts presented.

d. Interspousal gifts during the marriage. An interspousal gift of real property may not be made in the absence of a writing that complies with the requirements of s. 689.01. The joinder of a spouse in the execution of a deed with the sole purpose of the conveyance of homestead real property to any person or entity other than the other spouse or both spouses jointly does not change the character of the real property being conveyed, or any proceeds from the sale thereof, to marital property.

e. All vested and nonvested benefits, rights, and funds accrued during the marriage in retirement, pension, profit-sharing, annuity, deferred compensation, and insurance plans and programs.

f. The marital interests in a closely held business. The court shall determine the value of the marital interests in a closely held business as follows:

(I) The standard of value of a closely held business is fair market value. For purposes of this sub-subparagraph, the term “fair market value” means the price at which property would change hands between a willing and able buyer and a willing and able seller, with neither party under compulsion to buy or sell, and when both parties have reasonable knowledge of the relevant facts.

(II) If there is goodwill separate and distinct from the continued presence and reputation of the owner spouse, it is considered enterprise goodwill, which is a marital asset that must be valued by the court.

(III) The court must consider evidence that a covenant not to compete or a similar restrictive covenant may be required upon the sale of the closely held business, but such evidence alone does not preclude the court from finding enterprise goodwill.

2. All real property held by the parties as tenants by the entireties, whether acquired before or during the marriage, is presumed to be a marital asset. If, in any case, a party makes a claim to the contrary, the burden of proof is on the party asserting the claim that the subject property, or some portion thereof, is nonmarital.

3. All personal property titled jointly by the parties as tenants by the entireties, whether acquired before or during the marriage, is presumed to be a marital asset. In the event a party makes a claim to the contrary, the burden of proof is on the party asserting the claim that the subject property, or some portion thereof, is nonmarital.

4. The burden of proof to overcome the gift presumption is by clear and convincing evidence.

(b) “Nonmarital assets and liabilities” include all of the following:

1. Assets acquired and liabilities incurred by either party prior to the marriage, and assets acquired and liabilities incurred in exchange for such assets and liabilities.

2. Assets acquired separately by either party by noninterspousal gift, bequest, devise, or descent, and assets acquired in exchange for such assets.

3. All income derived from nonmarital assets during the marriage unless the income was treated, used, or relied upon by the parties as a marital asset.

4. Assets and liabilities excluded from marital assets and liabilities by valid written agreement of the parties, and assets acquired and liabilities incurred in exchange for such assets and liabilities.

5. Any liability incurred by forgery or unauthorized signature of one spouse signing the name of the other spouse. Any such liability is a nonmarital liability only of the party having committed the forgery or having affixed the unauthorized signature. In determining an award of attorney fees and costs pursuant to s. 61.16, the court may consider forgery or an unauthorized signature by a party and may make a separate award for attorney fees and costs occasioned by the forgery or unauthorized signature. This subparagraph does not apply to any forged or unauthorized signature that was subsequently ratified by the other spouse.

6. Real property acquired separately by either party by noninterspousal gift, bequest, devise, or descent for which legal title has not been transferred to the parties as tenants by the entireties in accordance with this section.

(7) The cut-off date for determining assets and liabilities to be identified or classified as marital assets and liabilities is the earliest of the date the parties enter into a valid separation agreement, such other date as may be expressly established by such agreement, or the date of the filing of a petition for dissolution of marriage. The date for determining value of assets and the amount of liabilities identified or classified as marital is the date or dates as the judge determines is just and equitable under the circumstances. Different assets may be valued as of different dates, as, in the judge’s discretion, the circumstances require.

(8) All assets acquired and liabilities incurred by either spouse subsequent to the date of the marriage and not specifically established as nonmarital assets or liabilities are presumed to be marital assets and liabilities. Such presumption is overcome by a showing that the assets and liabilities are nonmarital assets and liabilities. The presumption is only for evidentiary purposes in the dissolution proceeding and does not vest title. Title to disputed assets shall vest only by the judgment of a court. This section does not require the joinder of spouses in the conveyance, transfer, or hypothecation of a spouse’s individual property; affect the laws of descent and distribution; or establish community property in this state.

(9) The court may provide for equitable distribution of the marital assets and liabilities without regard to alimony for either party. After the determination of an equitable distribution of the marital assets and liabilities, the court shall consider whether a judgment for alimony shall be made.

(10)(a) To do equity between the parties, the court may, in lieu of or to supplement, facilitate, or effectuate the equitable division of marital assets and liabilities, order a monetary payment in a lump sum or in installments paid over a fixed period of time.

(b) If installment payments are ordered, the court may require security and a reasonable rate of interest or may otherwise recognize the time value of the money to be paid in the judgment or order.

(11) Special equity is abolished. All claims formerly identified as special equity, and all special equity calculations, are abolished and shall be asserted either as a claim for unequal distribution of marital property and resolved by the factors set forth in subsection (1) or as a claim of enhancement in value or appreciation of nonmarital property.

History.—s. 1, ch. 88-98; s. 2, ch. 91-246; s. 3, ch. 93-188; s. 1, ch. 94-204; s. 1, ch. 96-305; s. 1, ch. 2002-244; s. 1, ch. 2008-46; s. 1, ch. 2018-56; s. 1, ch. 2024-237.

Notes of Decisions

Cited in 920 cases (89 in the last 5 years), 1989–2026 · leading case: Kaaa v. Kaaa, 58 So. 3d 867 (Fla. 2011).

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Kaaa v. Kaaa, 58 So. 3d 867 (Fla. 2011). · cites it 21× “In 2008, section 61.075, Florida Statutes, was amended to include a new subsection (5).”

Calvin Callwood v. Toleatha Callwood, 221 So. 3d 1198 (Fla. 4th DCA 2017). · cites it 17× “However, the trial court did not actually factor the value of Estate Peterborg into the equitable distribution schedule, as the liability of Estate Peterborg’s negative value of ,700 is not shown as being distributed to either party. On appeal, the husband argues that the…”

Mathers v. Brown, 21 So. 3d 834 (Fla. 4th DCA 2009). · cites it 32× “Chapman and O'Neill involved the application of two subsections of section 61.075, Florida Statutes (2008). First, subsections 61.”

Ter Keurst v. Ter Keurst, 202 So. 3d 123 (Fla. 2d DCA 2016). · cites it 21× “The former husband asserts that this analysis failed to comply with the procedural requirements of section 61.075, and we agree. Generally stated, equitable distribution of marital assets is a three-step process: (1) identification of marital and nonmarital assets, (2) valuation…”

& SC16-589 Nancy Hooker v. Timothy I. Hooker & Timothy I. Hooker v. Nancy Hooker, 220 So. 3d 397 (Fla. 2017). · cites it 16× “Because it found that Hickstead should not be included in the equitable distribution, the Fourth District remanded the case to the trial court for a revised equitable distribution excluding Hickstead. Id. at 516. ANALYSIS The issue in this case is determining the appropriate…”

Amendments to the Florida Fam. Law Rules of Procedure & Fam. Law Forms, 810 So. 2d 1 (Fla. 2000). · cites it 14× “The Court should determine how the assets and liabilities of this marriage are to be distributed, under section 61.075, Florida Statutes. _ c. Petitioner should be awarded an interest in Respondent’s property because: SECTION II.”

Richardson v. Knight, 197 So. 3d 143 (Fla. 4th DCA 2016). · cites it 13× “In that situation, an equitable distribution scheme decided by the trial court must comply with section 61.075, Florida Statutes, which states in pertinent part: (3) In any contested dissolution action wherein a stipulation and agreement has not been entered and filed, any…”

Beers v. Beers, 724 So. 2d 109 (Fla. 5th DCA 1998). · cites it 18× “This factor is one of nine enumerated factors in subsection 61.075(1) which the trial court must consider in distributing the marital assets.”

Alpha v. Alpha, 885 So. 2d 1023 (Fla. 5th DCA 2004). · cites it 12× “See § 61.075, Fla. Stat.; Ruberg v. Ruberg, 858 So.”

Dorsett v. Dorsett, 902 So. 2d 947 (Fla. 4th DCA 2005). · cites it 10× “The trial court also erred by distributing the parties' assets without complying with the requirements of section 61.075, Florida Statutes. We find no error, however, in the trial court's requirement that the former wife contribute toward the mortgage during her period of…”

Acker v. Acker, 904 So. 2d 384 (Fla. 2005). · cites it 9× “See §§ 61.075, Fla. Stat. (2003) (equitable distribution); 61.”

Robertson v. Robertson, 593 So. 2d 491 (Fla. 1991). · cites it 8× “Section 61.075, Florida Statutes (1989), created a statutory form of equitable distribution.”

Show all 920 citing cases →

— 61.075(1) — 232 cases

Calvin Callwood v. Toleatha Callwood, 221 So. 3d 1198 (Fla. 4th DCA 2017). “However, the trial court did not actually factor the value of Estate Peterborg into the equitable distribution schedule, as the liability of Estate Peterborg’s negative value of ,700 is not shown as being distributed to either party. On appeal, the husband argues that the…”

Ter Keurst v. Ter Keurst, 202 So. 3d 123 (Fla. 2d DCA 2016). “The former husband asserts that this analysis failed to comply with the procedural requirements of section 61.075, and we agree. Generally stated, equitable distribution of marital assets is a three-step process: (1) identification of marital and nonmarital assets, (2) valuation…”

Amendments to the Florida Fam. Law Rules of Procedure & Fam. Law Forms, 810 So. 2d 1 (Fla. 2000). “The Court should determine how the assets and liabilities of this marriage are to be distributed, under section 61.075, Florida Statutes. _ c. Petitioner should be awarded an interest in Respondent’s property because: SECTION II.”

Amend. to Fl. Fam. Law Rules of Proc., 723 So. 2d 208 (Fla. 1998).

Krafchuk v. Krafchuk, 804 So. 2d 376 (Fla. 4th DCA 2001).

— 61.075(1)(a) — 21 cases

Harreld v. Harreld, 682 So. 2d 635 (Fla. 2d DCA 1996).

Silverman v. Silverman, 940 So. 2d 615 (Fla. 2d DCA 2006).

Williams v. Williams, 686 So. 2d 805 (Fla. 4th DCA 1997).

Bryan v. Bryan, 765 So. 2d 829 (Fla. 1st DCA 2000).

— 61.075(1)(b) — 4 cases

Bush v. Bush, 824 So. 2d 293 (Fla. 4th DCA 2002).

Bell v. Bell, 642 So. 2d 1173 (Fla. 1st DCA 1994).

Pierre-Louis v. Pierre-Louis, 715 So. 2d 1073 (Fla. 3d DCA 1998).

Kimberly Anne Crossen v. Michael Edward Feeley (Fla. 4th DCA 2026).

— 61.075(1)(c) — 4 cases

Williams v. Williams, 686 So. 2d 805 (Fla. 4th DCA 1997).

Lacoste v. Lacoste, 58 So. 3d 404 (Fla. 1st DCA 2011).

Berline Lapomarede v. Samuel Pierre (Fla. 4th DCA 2024).

Kimberly Anne Crossen v. Michael Edward Feeley (Fla. 4th DCA 2026).

— 61.075(1)(f) — 2 cases

Parry v. Parry, 933 So. 2d 9 (Fla. 2d DCA 2006).

Rivero v. Rivero, 963 So. 2d 934 (Fla. 3d DCA 2007).

— 61.075(1)(g) — 16 cases

Franklin v. Franklin, 988 So. 2d 125 (Fla. 2d DCA 2008).

Murray v. Murray, 636 So. 2d 536 (Fla. 1st DCA 1994).

Hallman v. Hallman, 575 So. 2d 738 (Fla. 5th DCA 1991).

Smith v. Smith, 934 So. 2d 636 (Fla. 2d DCA 2006).

Boutwell v. Adams, 920 So. 2d 151 (Fla. 1st DCA 2006).

— 61.075(1)(h) — 12 cases

Smith v. Smith, 912 So. 2d 702 (Fla. 2d DCA 2005).

Wrona v. Wrona, 592 So. 2d 694 (Fla. 2d DCA 1991).

Rodriguez v. Rodriguez, 994 So. 2d 1157 (Fla. 3d DCA 2008).

Bryan v. Bryan, 765 So. 2d 829 (Fla. 1st DCA 2000).

Thomas v. Thomas, 712 So. 2d 822 (Fla. 2d DCA 1998).

— 61.075(1)(i) — 22 cases

Beers v. Beers, 724 So. 2d 109 (Fla. 5th DCA 1998). “This factor is one of nine enumerated factors in subsection 61.075(1) which the trial court must consider in distributing the marital assets.”

Harreld v. Harreld, 682 So. 2d 635 (Fla. 2d DCA 1996).

Schneider v. Schneider, 864 So. 2d 1193 (Fla. 4th DCA 2004).

Segall v. Segall, 708 So. 2d 983 (Fla. 4th DCA 1998).

Crockett v. Crockett, 708 So. 2d 329 (Fla. 1st DCA 1998).

— 61.075(1)(j) — 20 cases

Smith v. Smith, 971 So. 2d 191 (Fla. 1st DCA 2007).

Boutwell v. Adams, 920 So. 2d 151 (Fla. 1st DCA 2006).

Rodriguez v. Rodriguez, 994 So. 2d 1157 (Fla. 3d DCA 2008).

Polacheck v. Polacheck, 2013 Ohio 5788 (Ohio Ct. App. 2013).

Tarleton v. Arnstein & Lehr, 719 So. 2d 325 (Fla. 4th DCA 1998).

— 61.075(10) — 6 cases

Gregory Rawson, Former Husband v. Lisa L. Rawson, Former Wife, 264 So. 3d 325 (Fla. 1st DCA 2019).

Teodoro Lopez v. Mariana Garcia Hernandez, 252 So. 3d 266 (Fla. 4th DCA 2018).

Fotinos v. Fotinos, 74 So. 3d 142 (Fla. 2d DCA 2011).

Evans v. Evans, 128 So. 3d 972 (Fla. 1st DCA 2013).

Ontario D. Johnson v. Lavelle P. Johnson (Fla. 4th DCA 2026).

— 61.075(10)(a) — 1 case

Grable v. Grable (Fla. 1st DCA 2026).

— 61.075(11) — 5 cases

Jurasek v. Jurasek, 67 So. 3d 1210 (Fla. 3d DCA 2011).

Teodoro Lopez v. Mariana Garcia Hernandez, 252 So. 3d 266 (Fla. 4th DCA 2018).

Davis v. Davis, 32 So. 3d 743 (Fla. 1st DCA 2010).

Gardiner v. Gardiner, 207 So. 3d 987 (Fla. 2d DCA 2016).

— 61.075(2) — 6 cases

GEICO Fin. Servs., Inc. v. Kramer, 575 So. 2d 1345 (Fla. 4th DCA 1991).

Adams v. Adams, 677 So. 2d 6 (Fla. 5th DCA 1996).

Shaver v. Shaver, 203 So. 3d 932 (Fla. 2d DCA 2016).

Grable v. Grable (Fla. 1st DCA 2026).

Haslauer v. Haslauer (Fla. 1st DCA 2024).

— 61.075(3) — 228 cases

Richardson v. Knight, 197 So. 3d 143 (Fla. 4th DCA 2016). “In that situation, an equitable distribution scheme decided by the trial court must comply with section 61.075, Florida Statutes, which states in pertinent part: (3) In any contested dissolution action wherein a stipulation and agreement has not been entered and filed, any…”

Alpha v. Alpha, 885 So. 2d 1023 (Fla. 5th DCA 2004). “See § 61.075, Fla. Stat.; Ruberg v. Ruberg, 858 So.”

Kennedy v. Kennedy, 622 So. 2d 1033 (Fla. 5th DCA 1993).

Dorsett v. Dorsett, 902 So. 2d 947 (Fla. 4th DCA 2005). “The trial court also erred by distributing the parties' assets without complying with the requirements of section 61.075, Florida Statutes. We find no error, however, in the trial court's requirement that the former wife contribute toward the mortgage during her period of…”

— 61.075(3)(a) — 36 cases

Straley v. Frank, 612 So. 2d 610 (Fla. 2d DCA 1992).

Robertson v. Robertson, 593 So. 2d 491 (Fla. 1991). “Section 61.075, Florida Statutes (1989), created a statutory form of equitable distribution.”

Young v. Young, 606 So. 2d 1267 (Fla. 1st DCA 1992).

Deas v. Deas, 592 So. 2d 1221 (Fla. 1st DCA 1992).

Bateh v. Bateh, 98 So. 3d 750 (Fla. 1st DCA 2012).

— 61.075(3)(a)(1) — 2 cases

Polley v. Polley, 588 So. 2d 638 (Fla. 3d DCA 1991).

Ray v. Ray, 624 So. 2d 1146 (Fla. 1st DCA 1993).

— 61.075(3)(a)(2) — 2 cases

Villaverde v. Villaverde, 547 So. 2d 185 (Fla. 3d DCA 1989).

Parker v. Parker, 610 So. 2d 719 (Fla. 1st DCA 1992).

— 61.075(3)(a)(4) — 1 case

DeLoach v. DeLoach, 590 So. 2d 956 (Fla. 1st DCA 1991).

— 61.075(3)(a)(5) — 6 cases

Straley v. Frank, 612 So. 2d 610 (Fla. 2d DCA 1992).

Glover v. Glover, 601 So. 2d 231 (Fla. 1st DCA 1992).

Ray v. Ray, 624 So. 2d 1146 (Fla. 1st DCA 1993).

Parker v. Parker, 610 So. 2d 719 (Fla. 1st DCA 1992).

Gregson v. Gregson, 739 So. 2d 1266 (Fla. 2d DCA 1999).

— 61.075(3)(b) — 34 cases

Esaw v. Esaw, 965 So. 2d 1261 (Fla. 2d DCA 2007).

Cintron v. King, 961 So. 2d 1010 (Fla. 4th DCA 2007).

Silverman v. Silverman, 940 So. 2d 615 (Fla. 2d DCA 2006).

Reich v. Reich, 652 So. 2d 1200 (Fla. 4th DCA 1995).

— 61.075(3)(b)(2) — 2 cases

Ray v. Ray, 624 So. 2d 1146 (Fla. 1st DCA 1993).

Polley v. Polley, 588 So. 2d 638 (Fla. 3d DCA 1991).

— 61.075(3)(c) — 15 cases

Jordan v. Jordan, 199 So. 3d 343 (Fla. 4th DCA 2016).

Vaccaro v. Vaccaro, 677 So. 2d 918 (Fla. 5th DCA 1996).

Green v. Green, 788 So. 2d 1083 (Fla. 1st DCA 2001).

Segall v. Segall, 708 So. 2d 983 (Fla. 4th DCA 1998).

Barabas v. Barabas, 923 So. 2d 588 (Fla. 5th DCA 2006).

— 61.075(3)(d) — 26 cases

Mondello v. Torres, 47 So. 3d 389 (Fla. 4th DCA 2010).

Fulmer v. Fulmer, 961 So. 2d 1081 (Fla. 1st DCA 2007).

Jordan v. Jordan, 127 So. 3d 794 (Fla. 4th DCA 2013).

Guobaitis v. Sherrer, 18 So. 3d 28 (Fla. 3d DCA 2009).

Rogers v. Rogers, 12 So. 3d 288 (Fla. 2d DCA 2009).

— 61.075(4) — 27 cases

Moon v. Moon, 594 So. 2d 819 (Fla. 1st DCA 1992).

Dyson v. Dyson, 597 So. 2d 320 (Fla. 1st DCA 1992).

Wendroff v. Wendroff, 614 So. 2d 590 (Fla. 1st DCA 1993).

Nicewonder v. Nicewonder, 602 So. 2d 1354 (Fla. 1st DCA 1992).

Akers v. Akers, 582 So. 2d 1212 (Fla. 1st DCA 1991).

— 61.075(5) — 27 cases

Carollo v. Carollo, 920 So. 2d 16 (Fla. 3d DCA 2004).

Polley v. Polley, 588 So. 2d 638 (Fla. 3d DCA 1991).

Grieco v. Grieco, 917 So. 2d 1052 (Fla. 2d DCA 2006).

Just. v. Just., 80 So. 3d 405 (Fla. 1st DCA 2012).

Alpert v. Alpert, 886 So. 2d 999 (Fla. 2d DCA 2004).

— 61.075(5)(a) — 112 cases

Universal Ins. Co. of North Am. v. Warfel, 82 So. 3d 47 (Fla. 2012).

Boyett v. Boyett, 703 So. 2d 451 (Fla. 1997).

Mallard v. Mallard, 771 So. 2d 1138 (Fla. 2000).

Mathers v. Brown, 21 So. 3d 834 (Fla. 4th DCA 2009). “Chapman and O'Neill involved the application of two subsections of section 61.075, Florida Statutes (2008). First, subsections 61.”

Anson v. Anson, 772 So. 2d 52 (Fla. 5th DCA 2000).

— 61.075(5)(a)(1) — 7 cases

Pfrengle v. Pfrengle, 976 So. 2d 1134 (Fla. 2d DCA 2008).

Barner v. Barner, 716 So. 2d 795 (Fla. 4th DCA 1998).

Heinrich v. Heinrich, 609 So. 2d 94 (Fla. 3d DCA 1992).

Smith v. Smith, 934 So. 2d 636 (Fla. 2d DCA 2006).

Colwell v. Royal Int'l Trading Corp., 226 B.R. 714 (S.D. Fla. 1998).

— 61.075(5)(a)(2) — 24 cases

Kaaa v. Kaaa, 58 So. 3d 867 (Fla. 2011). “In 2008, section 61.075, Florida Statutes, was amended to include a new subsection (5).”

Mathers v. Brown, 21 So. 3d 834 (Fla. 4th DCA 2009). “Chapman and O'Neill involved the application of two subsections of section 61.075, Florida Statutes (2008). First, subsections 61.”

Adkins v. Adkins, 650 So. 2d 61 (Fla. 3d DCA 1995).

Martin v. Martin, 923 So. 2d 1236 (Fla. 1st DCA 2006).

Somasca v. Somasca, 171 So. 3d 780 (Fla. 2d DCA 2015).

— 61.075(5)(a)(3) — 3 cases

Rosenfeld v. Rosenfeld, 597 So. 2d 835 (Fla. 3d DCA 1992).

Macrae-billewicz v. Billewicz, 67 So. 3d 226 (Fla. 2d DCA 2010).

Van Duyne v. Van Duyne, 856 So. 2d 1094 (Fla. 1st DCA 2003).

— 61.075(5)(a)(4) — 15 cases

Acker v. Acker, 904 So. 2d 384 (Fla. 2005). “See §§ 61.075, Fla. Stat. (2003) (equitable distribution); 61.”

Gibbons v. Gibbons, 10 So. 3d 127 (Fla. 2d DCA 2009).

Kay v. Kay, 988 So. 2d 1273 (Fla. 5th DCA 2008).

Carollo v. Carollo, 920 So. 2d 16 (Fla. 3d DCA 2004).

Rumler v. Rumler, 932 So. 2d 1165 (Fla. 2d DCA 2006).

— 61.075(5)(a)(5) — 4 cases

Zangari v. Cunningham, 839 So. 2d 918 (Fla. 2d DCA 2003).

Pfrengle v. Pfrengle, 976 So. 2d 1134 (Fla. 2d DCA 2008).

Hay v. Hay, 934 So. 2d 21 (Fla. 4th DCA 2006).

Williams v. Williams, 766 So. 2d 1127 (Fla. 2d DCA 2000).

— 61.075(5)(a)(l) — 1 case

Rogers v. Rogers, 12 So. 3d 288 (Fla. 2d DCA 2009).

— 61.075(5)(b) — 48 cases

Mitchell v. Mitchell, 841 So. 2d 564 (Fla. 2d DCA 2003).

Farrior v. Farrior, 736 So. 2d 1177 (Fla. 1999).

Caruso v. Caruso, 814 So. 2d 498 (Fla. 4th DCA 2002).

Jensen v. Jensen, 824 So. 2d 315 (Fla. 1st DCA 2002).

Bateh v. Bateh, 98 So. 3d 750 (Fla. 1st DCA 2012).

— 61.075(5)(b)(1) — 3 cases

Heinrich v. Heinrich, 609 So. 2d 94 (Fla. 3d DCA 1992).

Winney v. Winney, 979 So. 2d 396 (Fla. 1st DCA 2008).

Witowski v. Witowski, 758 So. 2d 1181 (Fla. 2d DCA 2000).

— 61.075(5)(b)(2) — 7 cases

Martin v. Martin, 923 So. 2d 1236 (Fla. 1st DCA 2006).

Valentine v. Van Sickle, 42 So. 3d 267 (Fla. 2d DCA 2010).

Dyer v. Dyer, 658 So. 2d 148 (Fla. 4th DCA 1995).

Mills v. Mills, 845 So. 2d 230 (Fla. 3d DCA 2003).

Siegel v. Siegel, 967 So. 2d 349 (Fla. 3d DCA 2007).

— 61.075(5)(b)(3) — 1 case

Heinrich v. Heinrich, 609 So. 2d 94 (Fla. 3d DCA 1992).

— 61.075(5)(b)(l) — 3 cases

Conlan v. Conlan, 43 So. 3d 931 (Fla. 4th DCA 2010).

Rivers v. Rivers, 785 So. 2d 752 (Fla. 5th DCA 2001).

Jarmel v. Jarmel, 641 So. 2d 926 (Fla. 2d DCA 1994).

— 61.075(6) — 90 cases

Byers v. Byers, 910 So. 2d 336 (Fla. 4th DCA 2005).

Caruso v. Caruso, 814 So. 2d 498 (Fla. 4th DCA 2002).

Jensen v. Jensen, 824 So. 2d 315 (Fla. 1st DCA 2002).

Cleary v. Cleary, 872 So. 2d 299 (Fla. 2d DCA 2004).

Krafchuk v. Krafchuk, 804 So. 2d 376 (Fla. 4th DCA 2001).

— 61.075(6)(a) — 49 cases

& SC16-589 Nancy Hooker v. Timothy I. Hooker & Timothy I. Hooker v. Nancy Hooker, 220 So. 3d 397 (Fla. 2017). “Because it found that Hickstead should not be included in the equitable distribution, the Fourth District remanded the case to the trial court for a revised equitable distribution excluding Hickstead. Id. at 516. ANALYSIS The issue in this case is determining the appropriate…”

Arica Matyjaszek v. Kevin R. Matyjaszek, 255 So. 3d 372 (Fla. 4th DCA 2018).

Viscito v. Viscito, 214 So. 3d 736 (Fla. 3d DCA 2017).

Chehab v. Hamilton-Chehab, 45 So. 3d 533 (Fla. 5th DCA 2010).

Juan Carlos Julia v. Martha Julia, 263 So. 3d 795 (Fla. 4th DCA 2019).

— 61.075(6)(a)(1) — 1 case

Teresa Lovelass f/k/a Teresa Hutchinson v. Christopher Hutchinson, 250 So. 3d 701 (Fla. 4th DCA 2018).

— 61.075(6)(a)(1)(a) — 4 cases

Anthony v. Distefano v. Andrea L. Distefano, 253 So. 3d 1178 (Fla. 2d DCA 2018).

Irving D. Rivera v. Angelica Marie Rivera (Fla. 3d DCA 2023).

Uwan Lloyd Williams v. Shanice Regina Williams (Fla. 3d DCA 2026).

— 61.075(6)(a)(1)(b) — 3 cases

Somasca v. Somasca, 171 So. 3d 780 (Fla. 2d DCA 2015).

Parminne Pitamber v. Lakeram Shivbaran (Fla. 3d DCA 2025).

— 61.075(6)(a)(1)(c) — 2 cases

Kerrigan v. Est. of John Edward Kerrigan, Page (Fla. 2d DCA 2024).

Parminne Pitamber v. Lakeram Shivbaran (Fla. 3d DCA 2025).

— 61.075(6)(a)(1)(d) — 1 case

Scott Dominic Palmateer v. Nicole Jean Palmateer, 260 So. 3d 476 (Fla. 2d DCA 2018).

— 61.075(6)(a)(1)(e) — 2 cases

Kenneth Alan Pearson v. Shay Rae Pearson, 268 So. 3d 863 (Fla. 2d DCA 2019).

James Phillip Kincaid v. Debra Kincaid (Fla. 5th DCA 2024).

— 61.075(6)(a)(2) — 2 cases

United States v. Morales, 36 F. Supp. 3d 1276 (M.D. Fla. 2014).

— 61.075(6)(a)(3) — 1 case

Dravis v. Dravis, 170 So. 3d 849 (Fla. 2d DCA 2015).

— 61.075(6)(a)(4) — 1 case

Punsky v. Clay Cnty. Sheriff's Off., 18 So. 3d 577 (Fla. 1st DCA 2009).

— 61.075(6)(a)(5) — 1 case

David v. David, 58 So. 3d 336 (Fla. 5th DCA 2011).

— 61.075(6)(a)(l) — 1 case

Shinitzky v. Shinitzky, 16 So. 3d 168 (Fla. 4th DCA 2009).

— 61.075(6)(a)(l)(a) — 5 cases

Nelson v. Nelson, 206 So. 3d 818 (Fla. 2d DCA 2016).

Orloff v. Orloff, 67 So. 3d 271 (Fla. 2d DCA 2011).

Wagner v. Wagner, 136 So. 3d 718 (Fla. 2d DCA 2014).

Julia v. Julia, 146 So. 3d 516 (Fla. 4th DCA 2014).

Landrum v. Landrum, 212 So. 3d 486 (Fla. 1st DCA 2017).

— 61.075(6)(a)(l)(b) — 6 cases

Bair v. Bair, 214 So. 3d 750 (Fla. 2d DCA 2017).

Jordan v. Jordan, 127 So. 3d 794 (Fla. 4th DCA 2013).

Kaaa v. Kaaa, 58 So. 3d 867 (Fla. 2011). “In 2008, section 61.075, Florida Statutes, was amended to include a new subsection (5).”

Orloff v. Orloff, 67 So. 3d 271 (Fla. 2d DCA 2011).

Somasca v. Somasca, 171 So. 3d 780 (Fla. 2d DCA 2015).

— 61.075(6)(a)(l)(c) — 1 case

Vigo v. Vigo, 15 So. 3d 619 (Fla. 3d DCA 2009).

— 61.075(6)(b) — 22 cases

Bell v. Bell, 68 So. 3d 321 (Fla. 4th DCA 2011).

Mathers v. Brown, 21 So. 3d 834 (Fla. 4th DCA 2009). “Chapman and O'Neill involved the application of two subsections of section 61.075, Florida Statutes (2008). First, subsections 61.”

Dianne L. Hahamovitch n/k/a Dianne Lynn Hahamovitch v. Harry H. Hahamovitch, 174 So. 3d 983 (Fla. 2015).

Mondello v. Torres, 47 So. 3d 389 (Fla. 4th DCA 2010).

Gromet v. Jensen, 201 So. 3d 132 (Fla. 3d DCA 2015).

— 61.075(6)(b)(1) — 5 cases

Tradler v. Tradler, 100 So. 3d 735 (Fla. 2d DCA 2012).

Anthony v. Distefano v. Andrea L. Distefano, 253 So. 3d 1178 (Fla. 2d DCA 2018).

Serap Frederick v. Timothy Frederick, 257 So. 3d 1105 (Fla. 2d DCA 2018).

Irving D. Rivera v. Angelica Marie Rivera (Fla. 3d DCA 2023).

Uwan Lloyd Williams v. Shanice Regina Williams (Fla. 3d DCA 2026).

— 61.075(6)(b)(2) — 3 cases

Tradler v. Tradler, 100 So. 3d 735 (Fla. 2d DCA 2012).

Dravis v. Dravis, 170 So. 3d 849 (Fla. 2d DCA 2015).

Celso Corrales v. Jeanette Corrales (Fla. 3d DCA 2021).

— 61.075(6)(b)(3) — 1 case

Tradler v. Tradler, 100 So. 3d 735 (Fla. 2d DCA 2012).

— 61.075(6)(b)(i) — 1 case

Cilenti v. Cilenti, 192 So. 3d 673 (Fla. 2d DCA 2016).

— 61.075(6)(b)(l) — 5 cases

Nelson v. Nelson, 206 So. 3d 818 (Fla. 2d DCA 2016).

Orloff v. Orloff, 67 So. 3d 271 (Fla. 2d DCA 2011).

Neiditch v. Neiditch, 187 So. 3d 374 (Fla. 5th DCA 2016).

Landrum v. Landrum, 212 So. 3d 486 (Fla. 1st DCA 2017).

Shinitzky v. Shinitzky, 16 So. 3d 168 (Fla. 4th DCA 2009).

— 61.075(7) — 63 cases

Mathers v. Brown, 21 So. 3d 834 (Fla. 4th DCA 2009). “Chapman and O'Neill involved the application of two subsections of section 61.075, Florida Statutes (2008). First, subsections 61.”

John Thomas Gotro, Former Husband v. Catherine Suzanne Gotro, Former Wife, 218 So. 3d 494 (Fla. 1st DCA 2017).

Alpha v. Alpha, 885 So. 2d 1023 (Fla. 5th DCA 2004). “See § 61.075, Fla. Stat.; Ruberg v. Ruberg, 858 So.”

Tradler v. Tradler, 100 So. 3d 735 (Fla. 2d DCA 2012).

Fortune v. Fortune, 61 So. 3d 441 (Fla. 2d DCA 2011).

— 61.075(8) — 20 cases

Acker v. Acker, 821 So. 2d 1088 (Fla. 3d DCA 2002).

Nelson v. Nelson, 206 So. 3d 818 (Fla. 2d DCA 2016).

Anna Louise Krift v. Daryl Dean Obenour, 152 So. 3d 645 (Fla. 4th DCA 2014).

Reis v. Reis, 739 So. 2d 704 (Fla. 3d DCA 1999).

Furbee v. Barrow, 45 So. 3d 22 (Fla. 2d DCA 2010).

— 61.075(8)(d) — 1 case

Schriefer v. Schriefer, 800 So. 2d 699 (Fla. 5th DCA 2001).

— 61.075(9) — 11 cases

Levy v. Levy, 862 So. 2d 48 (Fla. 3d DCA 2003).

Beers v. Beers, 724 So. 2d 109 (Fla. 5th DCA 1998). “This factor is one of nine enumerated factors in subsection 61.075(1) which the trial court must consider in distributing the marital assets.”

Bd. of Trs. of Orlando Police Pension Plan v. Langford, 833 So. 2d 230 (Fla. 5th DCA 2002).

Holmes v. Holmes, 613 So. 2d 511 (Fla. 3d DCA 1993).

Roth v. Cortina, 59 So. 3d 163 (Fla. 3d DCA 2011).

— 61.075(a) — 2 cases

Steele v. Steele, 945 So. 2d 601 (Fla. 4th DCA 2006).

Kimm v. Kimm, 650 So. 2d 1119 (Fla. 5th DCA 1995).

— 61.075(g) — 2 cases

Franklin v. Franklin, 988 So. 2d 125 (Fla. 2d DCA 2008).

Barner v. Barner, 716 So. 2d 795 (Fla. 4th DCA 1998).

— 61.075(h) — 2 cases

Moody v. Newton, 264 So. 3d 292 (Fla. 5th DCA 2019).

— 61.075(l) — 2 cases

Rossi v. Rossi, 169 So. 3d 1233 (Fla. 5th DCA 2015).

— 61.075(l)(a) — 17 cases

Mobley v. Mobley, 18 So. 3d 724 (Fla. 2d DCA 2009).

Nancy Smith Schroll, Former Wife v. Stephen B. Schroll, Former Husband, 227 So. 3d 232 (Fla. 1st DCA 2017).

Robert N. Badgley, Jr. v. Maria Belen Sanchez, 165 So. 3d 742 (Fla. 4th DCA 2015).

Watson v. Watson, 124 So. 3d 340 (Fla. 1st DCA 2013).

Valladares v. Junco-Valladares, 30 So. 3d 519 (Fla. 3d DCA 2010).

— 61.075(l)(b) — 1 case

Nancy B. Hua v. Dennis H.L. Tsung, 222 So. 3d 584 (Fla. 4th DCA 2017).

— 61.075(l)(c) — 1 case

LaCoste v. LaCoste, 58 So. 3d 404 (Fla. 1st DCA 2011).

— 61.075(l)(g) — 5 cases

Mondello v. Torres, 47 So. 3d 389 (Fla. 4th DCA 2010).

LaCoste v. LaCoste, 58 So. 3d 404 (Fla. 1st DCA 2011).

Russ v. Russ, 576 So. 2d 414 (Fla. 3d DCA 1991).

Trusheim v. Trusheim, 643 So. 2d 686 (Fla. 2d DCA 1994).

William E. Weaver v. Lori Lynn Weaver, 174 So. 3d 482 (Fla. 4th DCA 2015).

— 61.075(l)(h) — 5 cases

Stough v. Stough, 18 So. 3d 601 (Fla. 1st DCA 2009).

Jordan v. Jordan, 127 So. 3d 794 (Fla. 4th DCA 2013).

Julia v. Julia, 146 So. 3d 516 (Fla. 4th DCA 2014).

Lerner v. Lerner, 708 So. 2d 1029 (Fla. 2d DCA 1998).

Tsatiris v. Tsatiris, 653 So. 2d 405 (Fla. 5th DCA 1995).

— 61.075(l)(i) — 8 cases

Guobaitis v. Sherrer, 18 So. 3d 28 (Fla. 3d DCA 2009).

Amos v. Amos, 99 So. 3d 979 (Fla. 1st DCA 2012).

Jones v. Jones, 51 So. 3d 547 (Fla. 1st DCA 2010).

Jessica Vilma Miller v. Michael Van Miller, 186 So. 3d 1128 (Fla. 4th DCA 2016).

Martinez v. Martinez, 219 So. 3d 259 (Fla. 5th DCA 2017).

— 61.075(l)(i)(j) — 1 case

Nassirou v. Nassirou, 117 So. 3d 451 (Fla. 1st DCA 2013).

— 61.075(l)(j) — 8 cases

Rabbath v. Farid, 4 So. 3d 778 (Fla. 1st DCA 2009).

Watson v. Watson, 124 So. 3d 340 (Fla. 1st DCA 2013).

Tilchin v. Tilchin, 51 So. 3d 596 (Fla. 2d DCA 2011).

Timothy I. Hooker v. Nancy Hooker, 174 So. 3d 507 (Fla. 4th DCA 2015).

Amos v. Amos, 99 So. 3d 979 (Fla. 1st DCA 2012).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.