Florida Statutes

Fla. Stat. § 61.08 (2025)

Alimony.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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61.08 Alimony.—

(1)(a) In a proceeding for dissolution of marriage, the court may grant alimony to either party in the form or forms of temporary, bridge-the-gap, rehabilitative, or durational alimony, as is equitable. In an award of alimony, the court may order periodic or lump sum payments. The court may consider the adultery of either spouse and any resulting economic impact in determining the amount of alimony, if any, to be awarded.

(b) The court shall make written findings of fact regarding the basis for awarding a form or any combination of forms of alimony, including the type of alimony and the length of time for which the alimony is awarded. The court may award a combination of forms of alimony or forms of payment, including lump sum payments, to provide greater economic assistance in order to allow the obligee to achieve self-support.

(2)(a) In determining whether to award support, maintenance, or alimony, the court shall first make a specific, factual determination as to whether the party seeking support, maintenance, or alimony has an actual need for it and whether the other party has the ability to pay support, maintenance, or alimony. The party seeking support, maintenance, or alimony has the burden of proving his or her need for support, maintenance, or alimony and the other party’s ability to pay support, maintenance, or alimony.

(b) When determining a support, maintenance, or alimony claim, the court shall include written findings of fact relative to the factors provided in subsection (3) supporting an award or denial of support, maintenance, or alimony, unless the denial is based upon a failure to establish a need for or ability to pay support, maintenance, or alimony. However, the court shall make written findings of fact as to the lack of need or lack of ability to pay in denying a request for support, maintenance, or alimony.

(3) If the court finds that the party seeking support, maintenance, or alimony has a need for it and that the other party has the ability to pay support, maintenance, or alimony, then in determining the proper form or forms of support, maintenance, or alimony under subsections (5)-(8), or a deviation therefrom, the court shall consider all of the following relevant factors, including, but not limited to:

(a) The duration of the marriage.

(b) The standard of living established during the marriage and the anticipated needs and necessities of life for each party after the entry of the final judgment.

(c) The age, physical, mental, and emotional condition of each party, including whether either party is physically or mentally disabled and the resulting impact on either the obligee’s ability to provide for his or her own needs or the obligor’s ability to pay alimony and whether such conditions are expected to be temporary or permanent.

(d) The resources and income of each party, including the income generated from both nonmarital and marital assets.

(e) The earning capacities, educational levels, vocational skills, and employability of the parties, including the ability of either party to obtain the necessary skills or education to become self-supporting or to contribute to his or her self-support prior to the termination of the support, maintenance, or alimony award.

(f) The contribution of each party to the marriage, including, but not limited to, services rendered in homemaking, child care, education, and career building of the other party.

(g) The responsibilities each party will have with regard to any minor children whom the parties have in common, with special consideration given to the need to care for a child with a mental or physical disability.

(h) Any other factor necessary for equity and justice between the parties, which shall be specifically identified in the written findings of fact. This may include a finding of a supportive relationship as provided for in s. 61.14(1)(b) or a reasonable retirement as provided for in s. 61.14(1)(c)1.

(4) To the extent necessary to protect an award of alimony, the court may order the obligor to purchase or maintain a life insurance policy or a bond, or to otherwise secure such alimony award with any other assets that may be suitable for that purpose. The court must make specific findings that there are special circumstances that warrant the purchase or maintenance of a life insurance policy or a bond to secure the alimony award. If the court orders a party to purchase or maintain a life insurance policy or a bond, the court may apportion the costs of such insurance or bond to either or both parties based upon a determination of the ability of the obligee and obligor to pay such costs.

(5) For purposes of determining alimony, there is a rebuttable presumption that a short-term marriage is a marriage having a duration of less than 10 years, a moderate-term marriage is a marriage having a duration between 10 and 20 years, and a long-term marriage is a marriage having a duration of 20 years or longer. The length of a marriage is the period of time from the date of marriage until the date of filing of an action for dissolution of marriage.

(6) Bridge-the-gap alimony may be awarded to provide support to a party in making the transition from being married to being single. Bridge-the-gap alimony assists a party with legitimate identifiable short-term needs. The length of an award of bridge-the-gap alimony may not exceed 2 years. An award of bridge-the-gap alimony terminates upon the death of either party or upon the remarriage of the obligee. An award of bridge-the-gap alimony is not modifiable in amount or duration.

(7)(a) Rehabilitative alimony may be awarded to assist a party in establishing the capacity for self-support through either:

1. The redevelopment of previous skills or credentials; or

2. The acquisition of education, training, or work experience necessary to develop appropriate employment skills or credentials.

(b) In order to award rehabilitative alimony, there must be a specific and defined rehabilitative plan included as a part of any order awarding rehabilitative alimony.

(d) An award of rehabilitative alimony may be modified or terminated in accordance with s. 61.14 based upon a substantial change in circumstances, upon noncompliance with the rehabilitative plan, or upon completion of the rehabilitative plan if the plan is completed before the length of the award of rehabilitative alimony expires.

(8)(a) Durational alimony may be awarded to provide a party with economic assistance for a set period of time. An award of durational alimony terminates upon the death of either party or upon the remarriage of the obligee. The amount of an award of durational alimony may be modified or terminated based upon a substantial change in circumstances in accordance with s. 61.14. Durational alimony may not be awarded following a marriage lasting less than 3 years. The length of an award of durational alimony may not be modified except under exceptional circumstances and may not exceed the length of the marriage except as set forth in this subsection.

(b) An award of durational alimony may not exceed 50 percent of the length of a short-term marriage, 60 percent of the length of a moderate-term marriage, or 75 percent of the length of a long-term marriage. Under exceptional circumstances, the court may extend the term of durational alimony by a showing of clear and convincing evidence that it is necessary after application of the factors in subsection (3) and upon consideration of all of the following additional factors:

1. The extent to which the obligee’s age and employability limit the obligee’s ability for self-support, either in whole or in part.

2. The extent to which the obligee’s available financial resources limit the obligee’s ability for self-support, either in whole or in part.

3. The extent to which the obligee is mentally or physically disabled or has been diagnosed with a mental or physical condition that has rendered, or will render, him or her incapable of self-support, either in whole or in part.

4. The extent to which the obligee is the caregiver to a mentally or physically disabled child, whether or not the child has attained the age of majority, who is common to the parties. Any extension terminates upon the child no longer requiring caregiving by the obligee, or upon death of the child, unless one of the other factors in this paragraph apply.

(c) The amount of durational alimony is the amount determined to be the obligee’s reasonable need, or an amount not to exceed 35 percent of the difference between the parties’ net incomes, whichever amount is less. Net income shall be calculated in conformity with s. 61.30(2) and (3), excluding spousal support paid pursuant to a court order in the action between the parties.

(9) The award of alimony may not leave the payor with significantly less net income than the net income of the recipient unless there are written findings of exceptional circumstances.

(10)(a) With respect to any order requiring the payment of alimony entered on or after January 1, 1985, unless paragraph (c) or paragraph (d) applies, the court shall direct in the order that the payments of alimony be made through the appropriate depository as provided in s. 61.181.

(b) With respect to any order requiring the payment of alimony entered before January 1, 1985, upon the subsequent appearance on or after that date of one or both parties before the court having jurisdiction for the purpose of modifying or enforcing the order or in any other proceeding related to the order or upon the application of either party, unless paragraph (c) or paragraph (d) applies, the court shall modify the terms of the order as necessary to direct that payments of alimony be made through the appropriate depository as provided in s. 61.181.

(d)1. If there is a minor child of the parties and both parties so request, the court may order that alimony payments need not be directed through the depository. In this case, the order of support must provide, or be deemed to provide, that either party may subsequently apply to the depository to require that payments be made through the depository. The court shall provide a copy of the order to the depository.

2. If subparagraph 1. applies, either party may subsequently file with the depository an affidavit alleging default or arrearages in payment and stating that the party wishes to initiate participation in the depository program. The party shall provide copies of the affidavit to the court and the other party or parties. Fifteen days after receipt of the affidavit, the depository shall notify all parties that future payments must be directed to the depository.

3. In IV-D cases, the IV-D agency has the same rights as the obligee in requesting that payments be made through the depository.

(11) The court shall apply this section to all initial petitions for dissolution of marriage or support unconnected with dissolution of marriage pending or filed on or after July 1, 2023.

History.—ss. 7, 12, Oct. 31, 1828; RS 1484; GS 1932; RGS 3195; CGL 4987; s. 1, ch. 23894, 1947; s. 1, ch. 63-145; s. 16, ch. 67-254; s. 10, ch. 71-241; s. 1, ch. 78-339; s. 1, ch. 84-110; s. 115, ch. 86-220; s. 2. ch. 88-98; s. 3, ch. 91-246; s. 1, ch. 2010-199; s. 79, ch. 2011-92; s. 1, ch. 2023-315.

Note.—Former s. 65.08.

Notes of Decisions

Cited in 881 cases (77 in the last 5 years), 1968–2026 · leading case: Kennedy v. Kennedy, 622 So. 2d 1033 (Fla. 5th DCA 1993).

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Kennedy v. Kennedy, 622 So. 2d 1033 (Fla. 5th DCA 1993). · cites it 36× “We recently reversed a judgment awarding permanent alimony because of the trial judge's failure to comply with section 61.08, and remanded for appropriate findings of fact.”

Donoff v. Donoff, 940 So. 2d 1221 (Fla. 4th DCA 2006). · cites it 16× “Section 61.08 makes clear that in determining any need for alimony, whether original or modification, the entire financial resources and income of the party seeking the award must be considered.”

JAMES S. WINDER, Former Husband v. Dian A. Winder, Former Wife, 152 So. 3d 836 (Fla. 1st DCA 2014). · cites it 15× “The final judgment, however, failed to include sufficient factual findings as required by section 61.08 to allow for a meaningful review of this award.”

Esaw v. Esaw, 965 So. 2d 1261 (Fla. 2d DCA 2007). · cites it 9× “The Claim of Inadequate Factual Findings The wife argues on appeal that the trial court erred in failing to make specific findings of fact supporting the alimony award and that the trial court erred in failing to value certain marital property when making the equitable…”

Acker v. Acker, 904 So. 2d 384 (Fla. 2005). · cites it 14× “[2] Section 61.08, Florida Statutes (1993), provided in pertinent part: (1) In a proceeding for dissolution of marriage, the court may grant alimony to either party which alimony may be rehabilitative or permanent in nature.”

Berger v. Berger, 201 So. 3d 819 (Fla. 4th DCA 2016). · cites it 24× “The- wife primarily argues that the court erred in not awarding her permanent alimony because: (1) even though the marriage was a long term marriage under section 61.08, Florida Statutes (2014), the court did not find that a rebut-table presumption existed in favor of permanent…”

Canakaris v. Canakaris, 382 So. 2d 1197 (Fla. 1980). · cites it 4× “" § 61.08, Fla. Stat. This Court recognized in Yandell v.”

Broemer v. Broemer, 109 So. 3d 284 (Fla. 1st DCA 2013). · cites it 13× “§ 61.08(2), Fla. Stat. (2011); Walker v. Walker, 85 So.”

Williamson v. Williamson, 367 So. 2d 1016 (Fla. 1979). · cites it 13× “Although we construe section 61.08, Florida Statutes (1975), to permit, and in some instances require, the consideration of evidence of adulterous conduct in a proceeding to determine a proper alimony award, it must be remembered that the primary standards to be used in…”

Sobelman v. Sobelman, 541 So. 2d 1153 (Fla. 1989). · cites it 12× “Section 61.08(3), Florida Statutes (1985), which governs this situation, provides: *1154 To the extent necessary to protect an award of alimony, the court may order any party who is ordered to pay alimony to purchase or maintain a life insurance policy or a bond, or to otherwise…”

Taylor v. Taylor, 177 So. 3d 1000 (Fla. 2d DCA 2015). · cites it 22× “We conclude that the judgment does not contain the findings necessary under section 61.08, Florida Statutes (2012), to support an award of durational alimony.”

Zold v. Zold, 911 So. 2d 1222 (Fla. 2005). · cites it 9× “" § 61.08(2), Fla. Stat. (2004). Similarly, the child support guidelines establish that the presumptive amount of support is based on the parties' "combined monthly available income.”

Show all 881 citing cases →

— 61.08(02) — 1 case

Lowman v. Lowman, 724 So. 2d 648 (Fla. 2d DCA 1999).

— 61.08(1) — 160 cases

Kennedy v. Kennedy, 622 So. 2d 1033 (Fla. 5th DCA 1993). “We recently reversed a judgment awarding permanent alimony because of the trial judge's failure to comply with section 61.08, and remanded for appropriate findings of fact.”

Freilich v. Freilich, 897 So. 2d 537 (Fla. 5th DCA 2005).

Williamson v. Williamson, 367 So. 2d 1016 (Fla. 1979). “Although we construe section 61.08, Florida Statutes (1975), to permit, and in some instances require, the consideration of evidence of adulterous conduct in a proceeding to determine a proper alimony award, it must be remembered that the primary standards to be used in…”

Esaw v. Esaw, 965 So. 2d 1261 (Fla. 2d DCA 2007). “The Claim of Inadequate Factual Findings The wife argues on appeal that the trial court erred in failing to make specific findings of fact supporting the alimony award and that the trial court erred in failing to value certain marital property when making the equitable…”

Williams v. Williams, 923 So. 2d 606 (Fla. 2d DCA 2006).

— 61.08(1)(a) — 5 cases

Donald Lloyd Edman v. Carlene Edman (Fla. 4th DCA 2025).

Stockdale v. Stockdale (Fla. 1st DCA 2025).

Amanda Sheff v. Michael Kevin Sheff (Fla. 4th DCA 2026).

Woodward v. Woodward (Fla. 2d DCA 2025).

Morgan v. Morgan (Fla. 2d DCA 2026).

— 61.08(1)(b) — 2 cases

Donald Lloyd Edman v. Carlene Edman (Fla. 4th DCA 2025).

John Knox Vill. of Cent. Florida, Inc. & Lesly Mompoint, as to Majestic Oaks v. Est. of Alma Jane Lawrence, by & Through Marian K. Castleman, Pers. Rep. (Fla. 5th DCA 2024).

— 61.08(10) — 2 cases

Griffitts v. Griffitts, 263 So. 3d 220 (Fla. 5th DCA 2019).

— 61.08(11) — 7 cases

Pablo Alfonso v. Jessica Gordon Alfonso (Fla. 4th DCA 2025).

Rosi Gaul v. Jeffrey Gaul (Fla. 6th DCA 2026).

Stockdale v. Stockdale (Fla. 1st DCA 2025).

Donald Lloyd Edman v. Carlene Edman (Fla. 4th DCA 2025).

John R. Secrist v. Elizabeth A. Secrist (Fla. 5th DCA 2025).

— 61.08(2) — 295 cases

Donoff v. Donoff, 940 So. 2d 1221 (Fla. 4th DCA 2006). “Section 61.08 makes clear that in determining any need for alimony, whether original or modification, the entire financial resources and income of the party seeking the award must be considered.”

JAMES S. WINDER, Former Husband v. Dian A. Winder, Former Wife, 152 So. 3d 836 (Fla. 1st DCA 2014). “The final judgment, however, failed to include sufficient factual findings as required by section 61.08 to allow for a meaningful review of this award.”

Nichols v. Nichols, 907 So. 2d 620 (Fla. 4th DCA 2005).

— 61.08(2)(a) — 65 cases

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

Castillo v. Castillo, 59 So. 3d 221 (Fla. 3d DCA 2011).

Engesser v. Engesser, 42 So. 3d 249 (Fla. 5th DCA 2010).

— 61.08(2)(b) — 4 cases

Searcey v. Searcey, 923 So. 2d 528 (Fla. 2d DCA 2006).

Crisoforo Estrada, Jr. v. Ana Luz Garcia (Fla. 3d DCA 2026).

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

Michael E. Holder, Former Husband v. Anna Marie Lopez, f/k/a Anna Marie Holder, Former Wife, 274 So. 3d 518 (Fla. 1st DCA 2019).

— 61.08(2)(c) — 6 cases

Levy v. Levy, 900 So. 2d 737 (Fla. 2d DCA 2005).

Mosbarger v. Mosbarger, 547 So. 2d 188 (Fla. 2d DCA 1989).

Harrison v. Harrison, 540 So. 2d 230 (Fla. 1st DCA 1989).

Niekamp v. Niekamp, 173 So. 3d 1106 (Fla. 2d DCA 2015).

Maysa Shouman v. Ossama Salama (Fla. 6th DCA 2025).

— 61.08(2)(d) — 40 cases

Acker v. Acker, 904 So. 2d 384 (Fla. 2005). “[2] Section 61.08, Florida Statutes (1993), provided in pertinent part: (1) In a proceeding for dissolution of marriage, the court may grant alimony to either party which alimony may be rehabilitative or permanent in nature.”

Zold v. Zold, 911 So. 2d 1222 (Fla. 2005). “" § 61.08(2), Fla. Stat. (2004). Similarly, the child support guidelines establish that the presumptive amount of support is based on the parties' "combined monthly available income.”

Beck v. Beck, 852 So. 2d 934 (Fla. 2d DCA 2003).

Borchard v. Borchard, 730 So. 2d 748 (Fla. 2d DCA 1999).

— 61.08(2)(e) — 11 cases

Jimenez v. Jimenez, 211 So. 3d 76 (Fla. 4th DCA 2017).

Shea v. Shea, 572 So. 2d 558 (Fla. 1st DCA 1990).

Broemer v. Broemer, 109 So. 3d 284 (Fla. 1st DCA 2013). “§ 61.08(2), Fla. Stat. (2011); Walker v. Walker, 85 So.”

Koscher v. Koscher, 201 So. 3d 736 (Fla. 4th DCA 2016).

Anemey K. Huertas Del Pino v. Carlos E. Huertas Del Pino, 229 So. 3d 838 (Fla. 4th DCA 2017).

— 61.08(2)(f) — 6 cases

Severs v. Severs, 426 So. 2d 992 (Fla. 5th DCA 1983).

Hughes v. Hughes, 438 So. 2d 146 (Fla. 3d DCA 1983).

Dinsmore v. Dinsmore, 623 So. 2d 638 (Fla. 1st DCA 1993).

Wright v. Wright, 509 So. 2d 329 (Fla. 3d DCA 1987).

Jesus Garcia v. Juliette Espinosa-garcia (Fla. 3d DCA 2021).

— 61.08(2)(g) — 33 cases

Elliott v. Elliott, 867 So. 2d 1198 (Fla. 5th DCA 2004).

Hornyak v. Hornyak, 48 So. 3d 858 (Fla. 4th DCA 2010).

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

— 61.08(2)(h) — 8 cases

Rosaler v. Rosaler, 219 So. 3d 840 (Fla. 4th DCA 2017).

Librizzi v. Librizzi, 228 So. 3d 593 (Fla. 2d DCA 2017).

Tarkow v. Tarkow, 128 So. 3d 82 (Fla. 2d DCA 2013).

Stacey Walker v. Kristi Walker, 274 So. 3d 1156 (Fla. 2d DCA 2019).

Rodney Lane Cooper v. Christine Quitco Cooper (Fla. 2d DCA 2019).

— 61.08(2)(i) — 11 cases

Sherlock v. Sherlock, 199 So. 3d 1039 (Fla. 4th DCA 2016).

Newman v. Newman, 221 So. 3d 642 (Fla. 4th DCA 2017).

Adelberg v. Adelberg, 142 So. 3d 895 (Fla. 4th DCA 2014).

Reginald J. Nolan v. Karen D. Nolan, 188 So. 3d 977 (Fla. 1st DCA 2016).

Robert Addie v. Onyx Coale, 179 So. 3d 534 (Fla. 4th DCA 2015).

— 61.08(2)(j) — 5 cases

Thelma Rowe-lewis v. Horace Lewis, 267 So. 3d 1039 (Fla. 4th DCA 2019).

Robert Addie v. Onyx Coale, 179 So. 3d 534 (Fla. 4th DCA 2015).

Jesus Garcia v. Juliette Espinosa-garcia (Fla. 3d DCA 2021).

Robin Fiala v. Joel Fiala (Fla. 4th DCA 2022).

Christopher L. Burke v. Maureen Kelly Burke, n/k/a Maureen Bridget Kelly (Fla. 2d DCA 2021).

— 61.08(3) — 99 cases

Sobelman v. Sobelman, 541 So. 2d 1153 (Fla. 1989). “Section 61.08(3), Florida Statutes (1985), which governs this situation, provides: *1154 To the extent necessary to protect an award of alimony, the court may order any party who is ordered to pay alimony to purchase or maintain a life insurance policy or a bond, or to otherwise…”

Fiveash v. Fiveash, 523 So. 2d 764 (Fla. 1st DCA 1988).

Kearley v. Kearley, 745 So. 2d 987 (Fla. 2d DCA 1999).

Ruberg v. Ruberg, 858 So. 2d 1147 (Fla. 2d DCA 2003).

Clark v. Clark, 509 So. 2d 364 (Fla. 4th DCA 1987).

— 61.08(3)(a) — 1 case

Donald Lloyd Edman v. Carlene Edman (Fla. 4th DCA 2025).

— 61.08(3)(c) — 2 cases

Parker v. Parker, 655 So. 2d 233 (Fla. 1st DCA 1995).

Jack Ralph Hakim v. Grace Ellen Hakim (Fla. 3d DCA 2023).

— 61.08(4) — 51 cases

Zinovoy v. Zinovoy, 50 So. 3d 763 (Fla. 2d DCA 2010).

Addie v. Coale, 120 So. 3d 44 (Fla. 4th DCA 2013).

Berger v. Berger, 201 So. 3d 819 (Fla. 4th DCA 2016). “The- wife primarily argues that the court erred in not awarding her permanent alimony because: (1) even though the marriage was a long term marriage under section 61.08, Florida Statutes (2014), the court did not find that a rebut-table presumption existed in favor of permanent…”

Sherlock v. Sherlock, 199 So. 3d 1039 (Fla. 4th DCA 2016).

Broemer v. Broemer, 109 So. 3d 284 (Fla. 1st DCA 2013). “§ 61.08(2), Fla. Stat. (2011); Walker v. Walker, 85 So.”

— 61.08(5) — 17 cases

Taylor v. Lutz, 134 So. 3d 1146 (Fla. 1st DCA 2014).

Broemer v. Broemer, 109 So. 3d 284 (Fla. 1st DCA 2013). “§ 61.08(2), Fla. Stat. (2011); Walker v. Walker, 85 So.”

Taylor v. Taylor, 177 So. 3d 1000 (Fla. 2d DCA 2015). “We conclude that the judgment does not contain the findings necessary under section 61.08, Florida Statutes (2012), to support an award of durational alimony.”

Crick v. Crick, 78 So. 3d 696 (Fla. 2d DCA 2012).

Dickson v. Dickson, 204 So. 3d 498 (Fla. 4th DCA 2016).

— 61.08(6) — 3 cases

Kruse v. Levesque, 192 So. 3d 1263 (Fla. 2d DCA 2016).

Golliner v. Golliner (Fla. 2d DCA 2026).

— 61.08(6)(a) — 1 case

Darlene S. Horton, Former Wife v. John D. Horton, Former Husband, 257 So. 3d 1197 (Fla. 1st DCA 2018).

— 61.08(6)(a)(1) — 1 case

Aaron Smith v. Julie N. Chevillet (Fla. 4th DCA 2025).

— 61.08(6)(b) — 5 cases

Dickson v. Dickson, 204 So. 3d 498 (Fla. 4th DCA 2016).

Margaretten v. Margaretten, 101 So. 3d 395 (Fla. 1st DCA 2012).

Kruse v. Levesque, 192 So. 3d 1263 (Fla. 2d DCA 2016).

Aaron Smith v. Julie N. Chevillet (Fla. 4th DCA 2025).

Golliner v. Golliner (Fla. 2d DCA 2026).

— 61.08(7) — 45 cases

Stark v. Stark, 192 So. 3d 632 (Fla. 5th DCA 2016).

Broemer v. Broemer, 109 So. 3d 284 (Fla. 1st DCA 2013). “§ 61.08(2), Fla. Stat. (2011); Walker v. Walker, 85 So.”

Hedden v. Hedden, 240 So. 3d 148 (Fla. 5th DCA 2018).

Addie v. Coale, 120 So. 3d 44 (Fla. 4th DCA 2013).

— 61.08(8) — 43 cases

Broemer v. Broemer, 109 So. 3d 284 (Fla. 1st DCA 2013). “§ 61.08(2), Fla. Stat. (2011); Walker v. Walker, 85 So.”

Margaretten v. Margaretten, 101 So. 3d 395 (Fla. 1st DCA 2012).

Herbst v. Herbst, 153 So. 3d 290 (Fla. 2d DCA 2014).

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

— 61.08(8)(a) — 2 cases

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

Golliner v. Golliner (Fla. 2d DCA 2026).

— 61.08(8)(b) — 4 cases

George Jack Beck v. Monika Tamas-Beck (Fla. 4th DCA 2025).

Golliner v. Golliner (Fla. 2d DCA 2026).

Donald Lloyd Edman v. Carlene Edman (Fla. 4th DCA 2025).

John R. Secrist v. Elizabeth A. Secrist (Fla. 5th DCA 2025).

— 61.08(8)(c) — 2 cases

Jayne Loconto v. Richard J. Loconto (Fla. 4th DCA 2025).

Golliner v. Golliner (Fla. 2d DCA 2026).

— 61.08(9) — 7 cases

Koski v. Koski, 98 So. 3d 93 (Fla. 4th DCA 2012).

Payton v. Payton, 109 So. 3d 280 (Fla. 1st DCA 2013).

Alberto Rabadan v. Ana Rabadan (Fla. 4th DCA 2021).

Ryan Crouse v. Nancy L. Crouse (Fla. 4th DCA 2023).

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

— 61.08(a) — 3 cases

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

Nousari v. Nousari, 94 So. 3d 704 (Fla. 4th DCA 2012).

Golliner v. Golliner (Fla. 2d DCA 2026).

— 61.08(b) — 1 case

Kranz v. Kranz, 737 So. 2d 1198 (Fla. 5th DCA 1999).

— 61.08(c) — 1 case

Jayne Loconto v. Richard J. Loconto (Fla. 4th DCA 2025).

— 61.08(d) — 1 case

Kovar v. Kovar, 648 So. 2d 177 (Fla. 4th DCA 1994).

— 61.08(f) — 1 case

Duttenhofer v. Duttenhofer, 474 So. 2d 251 (Fla. 3d DCA 1985).

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