Florida Statute 61.13001 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title VI
CIVIL PRACTICE AND PROCEDURE

Chapter 61
DISSOLUTION OF MARRIAGE; SUPPORT; TIME-SHARING

View Entire Chapter

F.S. 61.13001

61.13001 Parental relocation with a child.—

(1) DEFINITIONS.—As used in this section, the term:

(a) “Child” means any person who is under the jurisdiction of a state court pursuant to the Uniform Child Custody Jurisdiction and Enforcement Act or is the subject of any order granting to a parent or other person any right to time-sharing, residential care, kinship, or custody, as provided under state law.

(b) “Court” means the circuit court in an original proceeding which has proper venue and jurisdiction in accordance with the Uniform Child Custody Jurisdiction and Enforcement Act, the circuit court in the county in which either parent and the child reside, or the circuit court in which the original action was adjudicated.

(c) “Other person” means an individual who is not the parent, but with whom the child resides pursuant to court order, or who has the right of access to, time-sharing with, or visitation with the child.

(d) “Parent” means any person so named by court order or express written agreement who is subject to court enforcement or a person reflected as a parent on a birth certificate and who is entitled to access to or time-sharing with the child.

(e) “Relocation” means a change in the location of the principal residence of a parent or other person from his or her principal place of residence at the time of the last order establishing or modifying time-sharing, or at the time of filing the pending action to establish or modify time-sharing. The change of location must be at least 50 miles from that residence, and for at least 60 consecutive days not including a temporary absence from the principal residence for purposes of vacation, education, or the provision of health care for the child.

(2) RELOCATION BY AGREEMENT.—

(a) If the parents and every other person entitled to access to or time-sharing with the child agree to the relocation of the child, they may satisfy the requirements of this section by signing a written agreement that:

1. Reflects consent to the relocation;

2. Defines an access or time-sharing schedule for the nonrelocating parent and any other persons who are entitled to access or time-sharing; and

3. Describes, if necessary, any transportation arrangements related to access or time-sharing.

(b) If there is an existing cause of action, judgment, or decree of record pertaining to the child’s residence or a time-sharing schedule, the parties shall seek ratification of the agreement by court order without the necessity of an evidentiary hearing unless a hearing is requested, in writing, by one or more of the parties to the agreement within 10 days after the date the agreement is filed with the court. If a hearing is not timely requested, it shall be presumed that the relocation is in the best interest of the child and the court may ratify the agreement without an evidentiary hearing.

(3) PETITION TO RELOCATE.—Unless an agreement has been entered as described in subsection (2), a parent or other person seeking relocation must file a petition to relocate and serve it upon the other parent, and every other person entitled to access to or time-sharing with the child. The pleadings must be in accordance with this section:

(a) The petition to relocate must be signed under oath or affirmation under penalty of perjury and include:

1. A description of the location of the intended new residence, including the state, city, and specific physical address, if known.

2. The mailing address of the intended new residence, if not the same as the physical address, if known.

3. The home telephone number of the intended new residence, if known.

4. The date of the intended move or proposed relocation.

5. A detailed statement of the specific reasons for the proposed relocation. If one of the reasons is based upon a job offer that has been reduced to writing, the written job offer must be attached to the petition.

6. A proposal for the revised postrelocation schedule for access and time-sharing together with a proposal for the postrelocation transportation arrangements necessary to effectuate time-sharing with the child. Absent the existence of a current, valid order abating, terminating, or restricting access or time-sharing or other good cause predating the petition, failure to comply with this provision renders the petition to relocate legally insufficient.

7. Substantially the following statement, in all capital letters and in the same size type, or larger, as the type in the remainder of the petition:

A RESPONSE TO THE PETITION OBJECTING TO RELOCATION MUST BE MADE IN WRITING, FILED WITH THE COURT, AND SERVED ON THE PARENT OR OTHER PERSON SEEKING TO RELOCATE WITHIN 20 DAYS AFTER SERVICE OF THIS PETITION TO RELOCATE. IF YOU FAIL TO TIMELY OBJECT TO THE RELOCATION, THE RELOCATION WILL BE ALLOWED, UNLESS IT IS NOT IN THE BEST INTERESTS OF THE CHILD, WITHOUT FURTHER NOTICE AND WITHOUT A HEARING.

(b) The petition to relocate must be served on the other parent and on every other person entitled to access to and time-sharing with the child. If there is a pending court action regarding the child, service of process may be according to court rule. Otherwise, service of process shall be according to chapters 48 and 49 or via certified mail, restricted delivery, return receipt requested.

(c) A parent or other person seeking to relocate has a continuing duty to provide current and updated information required by this section when that information becomes known.

(d) If the other parent and any other person entitled to access to or time-sharing with the child fails to timely file a response objecting to the petition to relocate, it is presumed that the relocation is in the best interest of the child and that the relocation should be allowed, and the court shall, absent good cause, enter an order specifying that the order is entered as a result of the failure to respond to the petition and adopting the access and time-sharing schedule and transportation arrangements contained in the petition. The order may be issued in an expedited manner without the necessity of an evidentiary hearing. If a response is timely filed, the parent or other person may not relocate, and must proceed to a temporary hearing or trial and obtain court permission to relocate.

(e) Relocating the child without complying with the requirements of this subsection subjects the party in violation to contempt and other proceedings to compel the return of the child and may be taken into account by the court in any initial or postjudgment action seeking a determination or modification of the parenting plan or the access or time-sharing schedule as:

1. A factor in making a determination regarding the relocation of a child.

2. A factor in determining whether the parenting plan or the access or time-sharing schedule should be modified.

3. A basis for ordering the temporary or permanent return of the child.

4. Sufficient cause to order the parent or other person seeking to relocate the child to pay reasonable expenses and attorney’s fees incurred by the party objecting to the relocation.

5. Sufficient cause for the award of reasonable attorney’s fees and costs, including interim travel expenses incident to access or time-sharing or securing the return of the child.

(4) APPLICABILITY OF PUBLIC RECORDS LAW.—If the parent or other person seeking to relocate a child, or the child, is entitled to prevent disclosure of location information under a public records exemption, the court may enter any order necessary to modify the disclosure requirements of this section in compliance with the public records exemption.

(5) OBJECTION TO RELOCATION.—An answer objecting to a proposed relocation must be verified and include the specific factual basis supporting the reasons for seeking a prohibition of the relocation, including a statement of the amount of participation or involvement the objecting party currently has or has had in the life of the child.

(6) TEMPORARY ORDER.—

(a) The court may grant a temporary order restraining the relocation of a child, order the return of the child, if a relocation has previously taken place, or order other appropriate remedial relief, if the court finds:

1. That the petition to relocate does not comply with subsection (3);

2. That the child has been relocated without a written agreement of the parties or without court approval; or

3. From an examination of the evidence presented at the preliminary hearing that there is a likelihood that upon final hearing the court will not approve the relocation of the child.

(b) The court may grant a temporary order permitting the relocation of the child pending final hearing, if the court finds:

1. That the petition to relocate was properly filed and is otherwise in compliance with subsection (3); and

2. From an examination of the evidence presented at the preliminary hearing, that there is a likelihood that on final hearing the court will approve the relocation of the child, which findings must be supported by the same factual basis as would be necessary to support approving the relocation in a final judgment.

(c) If the court has issued a temporary order authorizing a party seeking to relocate or move a child before a final judgment is rendered, the court may not give any weight to the temporary relocation as a factor in reaching its final decision.

(d) If temporary relocation of a child is approved, the court may require the person relocating the child to provide reasonable security, financial or otherwise, and guarantee that the court-ordered contact with the child will not be interrupted or interfered with by the relocating party.

(7) NO PRESUMPTION; FACTORS TO DETERMINE CONTESTED RELOCATION.—A presumption in favor of or against a request to relocate with the child does not arise if a parent or other person seeks to relocate and the move will materially affect the current schedule of contact, access, and time-sharing with the nonrelocating parent or other person. In reaching its decision regarding a proposed temporary or permanent relocation, the court shall evaluate all of the following:

(a) The nature, quality, extent of involvement, and duration of the child’s relationship with the parent or other person proposing to relocate with the child and with the nonrelocating parent, other persons, siblings, half-siblings, and other significant persons in the child’s life.

(b) The age and developmental stage of the child, the needs of the child, and the likely impact the relocation will have on the child’s physical, educational, and emotional development, taking into consideration any special needs of the child.

(c) The feasibility of preserving the relationship between the nonrelocating parent or other person and the child through substitute arrangements that take into consideration the logistics of contact, access, and time-sharing, as well as the financial circumstances of the parties; whether those factors are sufficient to foster a continuing meaningful relationship between the child and the nonrelocating parent or other person; and the likelihood of compliance with the substitute arrangements by the relocating parent or other person once he or she is out of the jurisdiction of the court.

(d) The child’s preference, taking into consideration the age and maturity of the child.

(e) Whether the relocation will enhance the general quality of life for both the parent or other person seeking the relocation and the child, including, but not limited to, financial or emotional benefits or educational opportunities.

(f) The reasons each parent or other person is seeking or opposing the relocation.

(g) The current employment and economic circumstances of each parent or other person and whether the proposed relocation is necessary to improve the economic circumstances of the parent or other person seeking relocation of the child.

(h) That the relocation is sought in good faith and the extent to which the objecting parent has fulfilled his or her financial obligations to the parent or other person seeking relocation, including child support, spousal support, and marital property and marital debt obligations.

(i) The career and other opportunities available to the objecting parent or other person if the relocation occurs.

(j) A history of substance abuse or domestic violence as defined in s. 741.28 or which meets the criteria of s. 39.806(1)(d) by either parent, including a consideration of the severity of such conduct and the failure or success of any attempts at rehabilitation.

(k) Any other factor affecting the best interest of the child or as set forth in s. 61.13.

(8) BURDEN OF PROOF.—The parent or other person wishing to relocate has the burden of proving by a preponderance of the evidence that relocation is in the best interest of the child. If that burden of proof is met, the burden shifts to the nonrelocating parent or other person to show by a preponderance of the evidence that the proposed relocation is not in the best interest of the child.

(9) ORDER REGARDING RELOCATION.—If relocation is approved:

(a) The court may, in its discretion, order contact with the nonrelocating parent or other person, including access, time-sharing, telephone, Internet, webcam, and other arrangements sufficient to ensure that the child has frequent, continuing, and meaningful contact with the nonrelocating parent or other person, if contact is financially affordable and in the best interest of the child.

(b) If applicable, the court shall specify how the transportation costs are to be allocated between the parents and other persons entitled to contact, access, and time-sharing and may adjust the child support award, as appropriate, considering the costs of transportation and the respective net incomes of the parents in accordance with the state child support guidelines schedule.

(10) PRIORITY FOR HEARING OR TRIAL.—An evidentiary hearing or nonjury trial on a pleading seeking temporary or permanent relief filed under this section shall be accorded priority on the court’s calendar. If a motion seeking a temporary relocation is filed, absent good cause, the hearing must occur no later than 30 days after the motion for a temporary relocation is filed. If a notice to set the matter for a nonjury trial is filed, absent good cause, the nonjury trial must occur no later than 90 days after the notice is filed.

(11) APPLICABILITY.—

(a) This section applies:

1. To orders entered before October 1, 2009, if the existing order defining custody, primary residence, the parenting plan, time-sharing, or access to or with the child does not expressly govern the relocation of the child.

2. To an order, whether temporary or permanent, regarding the parenting plan, custody, primary residence, time-sharing, or access to the child entered on or after October 1, 2009.

3. To any relocation or proposed relocation, whether permanent or temporary, of a child during any proceeding pending on October 1, 2009, wherein the parenting plan, custody, primary residence, time-sharing, or access to the child is an issue.

(b) To the extent that a provision of this section conflicts with an order existing on October 1, 2009, this section does not apply to the terms of that order which expressly govern relocation of the child or a change in the principal residence address of a parent or other person.

History.—s. 2, ch. 2006-245; s. 9, ch. 2008-61; s. 5, ch. 2009-21; s. 4, ch. 2009-180.

F.S. 61.13001 on Google Scholar

F.S. 61.13001 on CourtListener

Amendments to 61.13001

Annotations, Discussions, Cases:

Cases Citing Statute 61.13001

Total Results: 123

Scariti v. Sabillon

16 So. 3d 144, 2009 Fla. App. LEXIS 4208, 34 Fla. L. Weekly Fed. D 901

District Court of Appeal of Florida | Filed: May 6, 2009 | Docket: 1641350

Cited 10 times | Published

the trial court mistakenly concluded that section 61.13001, Florida Statutes (2007), ("the relocation

Fredman v. Fredman

960 So. 2d 52, 2007 WL 1756970

District Court of Appeal of Florida | Filed: Jun 20, 2007 | Docket: 1407324

Cited 10 times | Published

amended version of the relocation statute in section 61.13001 but applies only to the version of the statute

Rossman v. Profera

67 So. 3d 363, 2011 Fla. App. LEXIS 11755, 2011 WL 3110165

District Court of Appeal of Florida | Filed: Jul 27, 2011 | Docket: 2361986

Cited 9 times | Published

she is out of the jurisdiction of the court. § 61.13001(7)(c), Fla. Stat. (2008) (emphasis added). Ultimately

Cecemski v. Cecemski

954 So. 2d 1227, 2007 WL 1159705

District Court of Appeal of Florida | Filed: Apr 20, 2007 | Docket: 1651730

Cited 9 times | Published

requirements were implemented in the newly added section 61.13001, effective October 1, 2006. See ch.2006-245

Arthur v. Arthur

54 So. 3d 454, 35 Fla. L. Weekly Supp. 38, 2010 Fla. LEXIS 41, 2010 WL 114532

Supreme Court of Florida | Filed: Jan 14, 2010 | Docket: 60298289

Cited 8 times | Published

review to resolve this conflict. ANALYSIS Section 61.13001, Florida Statutes (2006), titled “Parental

Muller v. Muller

964 So. 2d 732, 2007 WL 2188337

District Court of Appeal of Florida | Filed: Aug 1, 2007 | Docket: 1240834

Cited 7 times | Published

to support the trial court's findings under section 61.13001(7), Florida Statutes (2006).[1]Id. Further

Anna Louise Krift v. Daryl Dean Obenour

152 So. 3d 645, 2014 Fla. App. LEXIS 17909, 2014 WL 5614809

District Court of Appeal of Florida | Filed: Nov 5, 2014 | Docket: 2592854

Cited 5 times | Published

analysis. 54 So.3d at 459. *649 Section 61.13001(e), Florida Statutes (2012) defines “Relocation”

Milton v. Milton

113 So. 3d 1040, 2013 WL 2421040, 2013 Fla. App. LEXIS 8925

District Court of Appeal of Florida | Filed: Jun 5, 2013 | Docket: 60231402

Cited 5 times | Published

1st DCA 2011). Here, Mr. Milton relies on section 61.13001, Florida Statutes, and Raulerson, to assert

Solomon v. Solomon

221 So. 3d 652, 2017 WL 2457248, 2017 Fla. App. LEXIS 8300

District Court of Appeal of Florida | Filed: Jun 7, 2017 | Docket: 60268323

Cited 4 times | Published

based on the statutory factors provided in section 61.13001, Florida Statutes. Ultimately, the trial court

In Re Implementation of Committee on Privacy & Court Records Recommendations—Amendments to the Florida Rules of Civil Procedure

78 So. 3d 1045, 2011 Fla. LEXIS 3030, 2011 WL 5829543

Supreme Court of Florida | Filed: Nov 3, 2011 | Docket: 1227055

Cited 4 times | Published

the case involves relocation, pursuant to Section 61.13001, Florida Statutes, then a Relocation/Long

Velazquez v. Millan

963 So. 2d 852, 2007 WL 2254822

District Court of Appeal of Florida | Filed: Aug 8, 2007 | Docket: 1328457

Cited 4 times | Published

to do so. There is nothing wrong in this. See § 61.13001(7), Fla. Stat. (2006) (expressly stating that

Hull v. Hull

273 So. 3d 1135

District Court of Appeal of Florida | Filed: May 31, 2019 | Docket: 64717532

Cited 3 times | Published

County when he filed the instant petition under section 61.13001, Florida Statutes (2017), to allow him and

Dickson v. Dickson

169 So. 3d 287, 2015 Fla. App. LEXIS 10854, 2015 WL 4366487

District Court of Appeal of Florida | Filed: Jul 17, 2015 | Docket: 60248876

Cited 3 times | Published

does not expressly prohibit a move. Further, section 61.13001(e) defines “Relocation” as “a change in the

Eckert v. Eckert

107 So. 3d 1235, 2013 WL 692082, 2013 Fla. App. LEXIS 3199

District Court of Appeal of Florida | Filed: Feb 27, 2013 | Docket: 60228615

Cited 3 times | Published

to grant or deny relocation of a parent. See § 61.13001(7), Fla. Stat. (2012). That section requires

Essex v. Davis

116 So. 3d 445, 2012 WL 2015419, 2012 Fla. App. LEXIS 9073

District Court of Appeal of Florida | Filed: Jun 6, 2012 | Docket: 60232352

Cited 3 times | Published

pending a relocation hearing in conformity with section 61.13001, Florida Statutes (2010). The mother initiated

Raulerson v. Wright

60 So. 3d 487, 2011 Fla. App. LEXIS 5420, 2011 WL 1451762

District Court of Appeal of Florida | Filed: Apr 15, 2011 | Docket: 60300230

Cited 3 times | Published

had not complied with the requirements of section 61.13001, Florida Statutes (2009). In response to this

Coyle v. Coyle

8 So. 3d 1271, 2009 Fla. App. LEXIS 4252, 2009 WL 1260038

District Court of Appeal of Florida | Filed: May 8, 2009 | Docket: 1654273

Cited 3 times | Published

factors set forth in section 61.13001(7), Florida Statutes (2007). Section 61.13001(7) sets forth a lengthy

In re Amendments to the Florida Supreme Court Approved Family Law Forms

20 So. 3d 173, 34 Fla. L. Weekly Supp. 298, 2009 Fla. LEXIS 785, 2009 WL 775400

Supreme Court of Florida | Filed: Mar 26, 2009 | Docket: 60294181

Cited 3 times | Published

for relocation of a minor child, pursuant to section 61.13001, Florida Statutes, a proposed Parenting Plan

Amendments to Approved Family Law Forms

20 So. 3d 173

Supreme Court of Florida | Filed: Mar 26, 2009 | Docket: 751733

Cited 3 times | Published

for relocation of a minor child, pursuant to section 61.13001, Florida Statutes, a proposed Parenting Plan

Miller v. Miller

992 So. 2d 346, 2008 WL 4414259

District Court of Appeal of Florida | Filed: Oct 1, 2008 | Docket: 1723656

Cited 3 times | Published

in Atlanta, Georgia and in accordance with section 61.13001 of the Florida Statutes sought permission

Norris v. Heckerman

972 So. 2d 1098, 33 Fla. L. Weekly Fed. D 358

District Court of Appeal of Florida | Filed: Jan 28, 2008 | Docket: 1650861

Cited 3 times | Published

relocation pursuant to the factors enumerated in section 61.13001(7), Florida Statutes (2006). Under this provision

Paskiewicz v. Paskiewicz

967 So. 2d 277, 2007 WL 2780902

District Court of Appeal of Florida | Filed: Sep 26, 2007 | Docket: 1454489

Cited 3 times | Published

responsibility with a primary residential custodian.[5]See § 61.13001(7), Fla. Stat. (2006) (listing factors to be

Buschor v. Buschor

252 So. 3d 833

District Court of Appeal of Florida | Filed: Aug 1, 2018 | Docket: 64686087

Cited 2 times | Published

factors regarding relocation set forth in section 61.13001, Florida Statutes (2015). With respect to

Ness v. Martinez

249 So. 3d 754

District Court of Appeal of Florida | Filed: Jun 13, 2018 | Docket: 64683355

Cited 2 times | Published

evidence supports the court's findings under section 61.13001(7), Florida Statutes. Muller v. Muller , 964

Riddle v. Riddle

214 So. 3d 694, 2017 WL 1177604, 2017 Fla. App. LEXIS 4178

District Court of Appeal of Florida | Filed: Mar 29, 2017 | Docket: 60264218

Cited 2 times | Published

misapplied the parental relocation statute, section 61.13001, Florida Statutes, is misplaced. The trial

Mata v. Mata

75 So. 3d 341, 2011 Fla. App. LEXIS 18181, 2011 WL 5554808

District Court of Appeal of Florida | Filed: Nov 16, 2011 | Docket: 60303696

Cited 2 times | Published

court below failed to follow the dictates of section 61.13001(6) of the Florida Statutes. That provision

A.F. v. R.P.B.

100 So. 3d 71, 2011 Fla. App. LEXIS 17456, 2011 WL 5253028

District Court of Appeal of Florida | Filed: Nov 4, 2011 | Docket: 60225924

Cited 2 times | Published

to explain our holding that the version of section 61.13001, Florida Statutes, effective until September

Howle v. Howle

967 So. 2d 435, 2007 WL 3170184

District Court of Appeal of Florida | Filed: Oct 31, 2007 | Docket: 1454333

Cited 2 times | Published

different requirements by the newly added section 61.13001(7). However, the new section does not apply

Vivian v. Schembari

966 So. 2d 492, 2007 WL 3010024

District Court of Appeal of Florida | Filed: Oct 17, 2007 | Docket: 2546133

Cited 2 times | Published

court denied relief, citing to the factors in section 61.13001(7), Florida Statutes (2006). We affirm the

Matias v. Matias

948 So. 2d 1021, 2007 WL 542114

District Court of Appeal of Florida | Filed: Feb 23, 2007 | Docket: 1764118

Cited 2 times | Published

will now be controlled by the provisions of section 61.13001, Florida Statutes (2006). Affirmed in part

Sanabria v. Sanabria

271 So. 3d 1101

District Court of Appeal of Florida | Filed: Feb 20, 2019 | Docket: 14560211

Cited 1 times | Published

consistent with the burden of proof as set forth in section 61.13001(8), Florida Statutes (2017). I. SUMMARY

RAYNESSA PARRIS v. IN THE MATTER OF: SHANTA BUTLER

264 So. 3d 1089

District Court of Appeal of Florida | Filed: Feb 8, 2019 | Docket: 14542364

Cited 1 times | Published

dissolution such that the relocation statute, section 61.13001, Florida Statutes (2017), did not apply;

RACHEL A. CHALMERS v. JOSEPH A. CHALMERS

259 So. 3d 878

District Court of Appeal of Florida | Filed: Nov 28, 2018 | Docket: 8338757

Cited 1 times | Published

court properly applied the relocation statute [section 61.13001, Florida Statutes] is a matter of law, reviewed

KRISTAL RYAN v. ROBERT RYAN

252 So. 3d 272

District Court of Appeal of Florida | Filed: Aug 8, 2018 | Docket: 7619145

Cited 1 times | Published

supplemental petition for relocation pursuant to section 61.13001, Florida Statutes (2017). The petition

Lane v. Lane

254 So. 3d 570

District Court of Appeal of Florida | Filed: Jul 11, 2018 | Docket: 7406893

Cited 1 times | Published

“prospective- based” analysis is unsound because section 61.13001(7), Florida Statutes (2006), which sets forth

Garcia v. Rivera

208 So. 3d 1183, 2017 Fla. App. LEXIS 38

District Court of Appeal of Florida | Filed: Jan 4, 2017 | Docket: 60258175

Cited 1 times | Published

Minor Child,” granting relocation pursuant to section 61.13001 of the Florida Statutes. We affirm because

Henderson-Bullard v. Lockard

204 So. 3d 568, 2016 Fla. App. LEXIS 17376

District Court of Appeal of Florida | Filed: Nov 18, 2016 | Docket: 4544022

Cited 1 times | Published

When no objection was filed as required by section 61.13001(7)(d), Florida Statutes (2016), the mother

Golson v. Golson

207 So. 3d 321, 2016 Fla. App. LEXIS 17371

District Court of Appeal of Florida | Filed: Nov 18, 2016 | Docket: 4544024

Cited 1 times | Published

to comply with the relocation provisions of section 61.13001, Florida Statutes (2013), if she attempted

Adel Valezadeh v. Mahnaz Hossaini

174 So. 3d 579, 2015 Fla. App. LEXIS 13074, 2015 WL 5145579

District Court of Appeal of Florida | Filed: Sep 2, 2015 | Docket: 2690052

Cited 1 times | Published

filed her petition for relocation pursuant to section 61.13001(3), Florida Statutes (2014), which states

Brooks v. Brooks

164 So. 3d 162, 2015 Fla. App. LEXIS 7270, 2015 WL 2260654

District Court of Appeal of Florida | Filed: May 15, 2015 | Docket: 2657318

Cited 1 times | Published

filing a petition to relocate pursuant to section 61.13001, Florida Statutes (2011). After the hearing

In re Amendments to the Florida Supreme Court Approved Family Law Forms

173 So. 3d 19

Supreme Court of Florida | Filed: Mar 26, 2015 | Docket: 60294087

Cited 1 times | Published

dependent or minor children and pursuant to Section 61.13001, Florida Statutes: 1. You plan to relocate

Wing v. Wing

129 So. 3d 1116, 2013 WL 6690680, 2013 Fla. App. LEXIS 20107

District Court of Appeal of Florida | Filed: Dec 20, 2013 | Docket: 60237300

Cited 1 times | Published

failed to apply the explicit directives in section 61.13001(3), Florida Statutes (2009). While we do not

In re Amendments to Florida Supreme Court Approved Family Law Forms

122 So. 3d 320, 38 Fla. L. Weekly Supp. 617, 2013 WL 4734603, 2013 Fla. LEXIS 1892

Supreme Court of Florida | Filed: Sep 4, 2013 | Docket: 60234662

Cited 1 times | Published

parent or other person in accordance with section 61.13001, Florida Statutes. Respondent — the person

Shiba v. Gabay

120 So. 3d 80, 2013 WL 4006132, 2013 Fla. App. LEXIS 12363

District Court of Appeal of Florida | Filed: Aug 7, 2013 | Docket: 60234270

Cited 1 times | Published

61.13, as well as the relocation statute, section 61.13001. What the court felt most important was the

Rivero v. Rivero

111 So. 3d 233, 2013 WL 1439731, 2013 Fla. App. LEXIS 5731

District Court of Appeal of Florida | Filed: Apr 10, 2013 | Docket: 60230781

Cited 1 times | Published

relocation, contrary to the requirements of section 61.13001(6)(b), Florida Statutes. See Mata v. Mata

Edgar v. Firuta

100 So. 3d 255, 2012 Fla. App. LEXIS 19146, 2012 WL 5416432

District Court of Appeal of Florida | Filed: Nov 7, 2012 | Docket: 60225747

Cited 1 times | Published

regarding the proposed relocation, pursuant to section 61.13001, Florida Statutes (2010), as well as a detailed

Orta v. Suarez

66 So. 3d 988, 2011 Fla. App. LEXIS 10161, 2011 WL 2555427

District Court of Appeal of Florida | Filed: Jun 29, 2011 | Docket: 2363186

Cited 1 times | Published

relocation with the child, we reverse.[2] Section 61.13001(7) of the Florida Statutes governing relocation

Gergen v. Gergen

48 So. 3d 148, 2010 Fla. App. LEXIS 18068, 2010 WL 4703852

District Court of Appeal of Florida | Filed: Nov 22, 2010 | Docket: 1926753

Cited 1 times | Published

3d —, —, 2010 WL 114532 (Fla.2010) (applying § 61.13001, Fla. Stat. governing relocation statute, trial

Lombard v. Lombard

997 So. 2d 1188, 2008 WL 5263637

District Court of Appeal of Florida | Filed: Dec 19, 2008 | Docket: 1379811

Cited 1 times | Published

parent's visitation rights"); (4)(c) (same); § 61.13001(2)(a) ("if the primary residential parent and

In Re BTG

993 So. 2d 1140, 2008 WL 4756399

District Court of Appeal of Florida | Filed: Oct 31, 2008 | Docket: 1516171

Cited 1 times | Published

between the child and the nonrelocating parent." § 61.13001(7)(c), Fla. Stat. (2006); see Fredman v. Fredman

Amanda Lee Lawler v. Brian Patrick Lawler

District Court of Appeal of Florida | Filed: Jun 4, 2025 | Docket: 70454066

Published

Father and the Father’s attempt to comply with section 61.13001(3)(a)(6), Florida Statute (2024), we affirm

Parminne Pitamber v. Lakeram Shivbaran

District Court of Appeal of Florida | Filed: May 21, 2025 | Docket: 70328219

Published

competent, substantial evidence of record. See § 61.13001(7), Fla. Stat. (2023); § 61.13(3), Fla. Stat

Lindsey Rachelle Healy v. Joseph James Healy

District Court of Appeal of Florida | Filed: Apr 23, 2025 | Docket: 69929828

Published

within the 50-mile radius permitted under section 61.13001(1)(e), Florida Statutes. At the time, the

Burgess v. Burgess

District Court of Appeal of Florida | Filed: Jan 31, 2025 | Docket: 69596398

Published

the best interests of the minor children. See § 61.13001(8), Fla. Stat. (2024); Coyle v. Coyle, 8 So.

Andrea Catalina Cruz v. Gerardo Morales

District Court of Appeal of Florida | Filed: Oct 16, 2024 | Docket: 69265879

Published

each of the requisite factors enumerated in section 61.13001, Florida Statutes (2023). “When reviewing

Allison Giacomaro v. Jonathan Brossia

District Court of Appeal of Florida | Filed: Oct 16, 2024 | Docket: 69266248

Published

regarding the relocation factors contained in section 61.13001, Florida Statutes (2023). The court ordered

Tefilah O. Blatt v. Aron N. Blatt

District Court of Appeal of Florida | Filed: Jun 12, 2024 | Docket: 68848626

Published

without filing a petition for relocation. See § 61.13001(3), Fla. Stat. (“Unless an agreement has been

Charles Edward Lane v. Samaria R. Fuller

District Court of Appeal of Florida | Filed: Jun 7, 2024 | Docket: 68313532

Published

be in accordance with” the relocation statute. § 61.13001(3), Fla. Stat. (2022) (emphasis added). Substantial

MICHAEL REX VANDERHOOF v. LAUREN BROOKE ARMSTRONG

District Court of Appeal of Florida | Filed: Mar 22, 2024 | Docket: 68366265

Published

petition for parental relocation pursuant to section 61.13001, Florida Statutes (2022), so that she could

Tammy R. Ward v. Joshua K. Waters

District Court of Appeal of Florida | Filed: Jan 3, 2024 | Docket: 68132274

Published

273 So. 3d 1135 (Fla. 5th DCA 2019), and section 61.13001, Florida Statutes (2022). We summarily affirm

ANTHONY T. LITSCH, III vs JULIE LITSCH N/K/A JULIE MILLS

District Court of Appeal of Florida | Filed: Oct 13, 2023 | Docket: 68034132

Published

Appellee correctly notes, it did not comply with section 61.13001(2)’s requirements that a relocation

FEDLINE INNOCENT v. RICO INNOCENT

District Court of Appeal of Florida | Filed: May 17, 2023 | Docket: 67400403

Published

iv. Any Relocation Order Must Comply With Section 61.13001 Finally, the Former Wife argues the circuit

JOHELI CRUZ WHITE v. KEVIN LEE-YUK

District Court of Appeal of Florida | Filed: Sep 21, 2022 | Docket: 65363939

Published

5 Under section 61.13001, Florida Statutes (2022), a party desiring

RALPH J. HERNANDEZ v. LISA ANN HERNANDEZ a/k/a LISA ANN HERNANDEZ-MCPAIL

District Court of Appeal of Florida | Filed: Mar 9, 2022 | Docket: 63144891

Published

pursuant to the relocation statute codified in section 61.13001, Florida Statutes (2019), from the mother’s

HEATHER MIGNOTT v. GARFIELD MIGNOTT

District Court of Appeal of Florida | Filed: Dec 22, 2021 | Docket: 61637665

Published

relocation with the minor child pursuant to section 61.13001, Florida Statutes, to which Mother objected

In Re: Amendments to the Florida Rules of Civil Procedure, Florida Rules of General Practice and Judicial Administration, Florida Rules of Criminal Procedure, Florida Probate Rules, Florida Rules of Traffic Court, Florida Small Claims Rules, Florida Rules of Juvenile Procedure, Florida Rules of Appellate Procedure, and Florida Family Law Rules of Procedure

Supreme Court of Florida | Filed: Oct 28, 2021 | Docket: 60688689

Published

or compliance with the requirements of section 61.13001, Florida Statutes. If the parenting coordinator

In Re: Amendments to the Florida Rules of Civil Procedure, Florida Rules of General Practice and Judicial Administration, Florida Rules of Criminal Procedure, Florida Probate Rules, Florida Rules of Traffic Court, Florida Small Claims Rules, Florida Rules of Juvenile Procedure, Florida Rules of Appellate Procedure, and Florida Family Law Rules of Procedure

Supreme Court of Florida | Filed: Oct 28, 2021 | Docket: 60680655

Published

or compliance with the requirements of section 61.13001, Florida Statutes. If the parenting coordinator

Susan Jennings v. Jose E. Arenas Fredes

District Court of Appeal of Florida | Filed: Sep 22, 2021 | Docket: 60414523

Published

this provisional award of timesharing. Under section 61.13001(3), Florida Statutes (2020), unless the parents

GUILLERMO IZAGUIRRE v. ANA JULIA SANCHEZ

District Court of Appeal of Florida | Filed: Aug 11, 2021 | Docket: 60123694

Published

ad litem address the statutory factors in section 61.13001 of the Florida Statutes when addressing whether

C.N. v. I.G.C.

Supreme Court of Florida | Filed: Apr 29, 2021 | Docket: 59864607

Published

Petitions to relocate a child are governed by section 61.13001, Florida Statutes (2020).

In Re: Amendments to the Florida Family Law Rules of Procedure - 2020 Regular-Cycle Report

Supreme Court of Florida | Filed: Nov 12, 2020 | Docket: 18620269

Published

or compliance with the requirements of section 61.13001, Florida Statutes. If the parenting coordinator

CHRISTOPHER CLARK v. BRITTANY MEIZLIK

District Court of Appeal of Florida | Filed: Jan 29, 2020 | Docket: 16773994

Published

court does not comply with the requirements of section 61.13001, Florida Statutes (2018). We agree and reverse

Meggan Elizabeth Miller v. Matthew Lee Miller

District Court of Appeal of Florida | Filed: Jul 16, 2019 | Docket: 15922578

Published

will approve the relocation at a final hearing. § 61.13001(6)(b), Fla. Stat. (2019). When making its relocation

Hull v. Hull

273 So. 3d 1135

District Court of Appeal of Florida | Filed: May 31, 2019 | Docket: 64717533

Published

County when he filed the instant petition under section 61.13001, Florida Statutes (2017), to allow him and

Rina Genise Couperthwaite, n/k/a Rina Genise Pollock, Former Wife v. David W. Couperthwaite, Former Husband

District Court of Appeal of Florida | Filed: May 6, 2019 | Docket: 15059366

Published

relocate with the minor child, pursuant to section 61.13001, Florida Statutes (2017). The portion of the

James Christopher Pearce, Former Husband v. Jennifer Boudreaux f/k/a Pearce, Former Wife

265 So. 3d 712

District Court of Appeal of Florida | Filed: Feb 28, 2019 | Docket: 14573450

Published

trial and obtain court permission to relocate. § 61.13001(3)(d), Fla. Stat. (emphasis added). The highlighted

Allende v. Veloz

273 So. 3d 142

District Court of Appeal of Florida | Filed: Feb 20, 2019 | Docket: 14560225

Published

to and must be sought in compliance with section 61.13001, Florida Statutes.” In November 2015

SARAH LYNDEN SAPONARA v. ERNEST ADRIAN CALEB SAPONARA

261 So. 3d 570

District Court of Appeal of Florida | Filed: Nov 21, 2018 | Docket: 8221307

Published

for the parent not seeking the move. Under section 61.13001(9), Florida Statutes (2017), if a trial court

Rivera v. Purtell

252 So. 3d 283

District Court of Appeal of Florida | Filed: Jun 18, 2018 | Docket: 7317157

Published

various factors outlined in section 61.13001(7) that the trial court is required to consider

Brooke Larae Ness f/k/a Brooke Larae Martinez v. Robert Jason Martinez

District Court of Appeal of Florida | Filed: Jun 13, 2018 | Docket: 7144548

Published

evidence supports the court’s findings under section 61.13001(7), Florida Statutes. Muller v. Muller, 964

JOSEPH CASTLEMAN v. JEANN SAGA BICALDO

248 So. 3d 1181

District Court of Appeal of Florida | Filed: Jun 6, 2018 | Docket: 7061993

Published

court did not comply with the dictates of section 61.13001, Florida Statutes (2017). It reasoned the

Marcy Nicole Overstreet, Wife v. Dwayne Stanley Overstreet, Husband

244 So. 3d 1182

District Court of Appeal of Florida | Filed: Apr 25, 2018 | Docket: 6375209

Published

13001.” § 61.13002(7), Fla. Stat. In turn, section 61.13001, although entitled “Parental relocation with

Gimonge v. Gimonge

239 So. 3d 1275

District Court of Appeal of Florida | Filed: Mar 19, 2018 | Docket: 6349215

Published

relocate with the couple’s minor child under section 61.13001, Florida Statutes (2017). We affirm.

In re Amendments to the Florida Supreme Court Approved Family Law Forms—Nomenclature

235 So. 3d 357

Supreme Court of Florida | Filed: Feb 1, 2018 | Docket: 60294212

Published

parent or other person in accordance with section 61.13001, Florida Statutes, Respondent—the person who

In Re: Amendments to the Florida Supreme Court Approved Family Law Forms - Nomenclature

235 So. 3d 357

Supreme Court of Florida | Filed: Feb 1, 2018 | Docket: 6289808

Published

parent or other person in accordance with section 61.13001, Florida Statutes. General Information for

Sickels v. Sickels

221 So. 3d 778, 2017 WL 2821720, 2017 Fla. App. LEXIS 9507

District Court of Appeal of Florida | Filed: Jun 30, 2017 | Docket: 6086564

Published

the minor children to Virginia pursuant to section 61.13001, Florida Statutes (2016). After an evidentia-ry

Kathleen Lynn Horn, Former Wife v. Mark Gordon Horn, Former Husband

225 So. 3d 292, 2017 Fla. App. LEXIS 364, 2017 WL 163691

District Court of Appeal of Florida | Filed: Jan 17, 2017 | Docket: 4568510

Published

relocate without meeting the requirements of Section 61.13001, Florida Statutes, and since it finds that

Garcia v. Rivera

District Court of Appeal of Florida | Filed: Jan 4, 2017 | Docket: 4561884

Published

Minor Child,” granting relocation pursuant to section 61.13001 of the Florida Statutes. We affirm because

Naime v. Corzo III

208 So. 3d 296, 2016 Fla. App. LEXIS 18674

District Court of Appeal of Florida | Filed: Dec 21, 2016 | Docket: 4555828

Published

requisite and applicable factors set forth in section 61.13001(7), Florida Statutes (2014), and articulated

Morell v. Ruiz

207 So. 3d 293, 2016 Fla. App. LEXIS 16672

District Court of Appeal of Florida | Filed: Nov 9, 2016 | Docket: 63631309

Published

petition for relocation under Florida Statute Section 61.13001 (2016). We reverse because that statute has

Morell v. Ruiz

District Court of Appeal of Florida | Filed: Nov 9, 2016 | Docket: 4486856

Published

petition for relocation under Florida Statute Section 61.13001 (2016). We reverse because that statute has

In Re AMENDMENTS TO the FLORIDA SUPREME COURT APPROVED FAMILY LAW FORMS

205 So. 3d 1, 40 Fla. L. Weekly Supp. 647, 2015 Fla. LEXIS 2607

Supreme Court of Florida | Filed: Nov 19, 2015 | Docket: 3014109

Published

dependent or minor children and pursuant to Section 61.13001, Florida Statutes: 1. You plan to relocate

T.B., the Father v. Department Of Children And Families

189 So. 3d 150, 2015 Fla. App. LEXIS 16009, 2015 WL 6496316

District Court of Appeal of Florida | Filed: Oct 28, 2015 | Docket: 3007732

Published

attorney contended that the court should apply section 61.13001, Florida Statutes (2014),,regarding relocation

Nicolas v. Blanc

178 So. 3d 430, 2015 Fla. App. LEXIS 14470, 40 Fla. L. Weekly Fed. D 2232

District Court of Appeal of Florida | Filed: Sep 30, 2015 | Docket: 2863181

Published

requisite and applicable factors set forth in section 61.13001(7), Florida Statutes (2014), and articulated

Fosshage v. Fosshage

167 So. 3d 525, 2015 Fla. App. LEXIS 10723, 2015 WL 4257864

District Court of Appeal of Florida | Filed: Jul 15, 2015 | Docket: 2674012

Published

under section 61.13(3) and relocation under section 61.13001 of the Florida Statutes. See Miller

Suleiman v. Yunis

168 So. 3d 319, 2015 Fla. App. LEXIS 9993, 2015 WL 4002327

District Court of Appeal of Florida | Filed: Jul 2, 2015 | Docket: 60248642

Published

judgment against relocation. Furthermore, section 61.13001(3), Florida Statutes (2014), which requires

Edgar v. Firuta

165 So. 3d 758, 2015 Fla. App. LEXIS 7558, 40 Fla. L. Weekly Fed. D 1184

District Court of Appeal of Florida | Filed: May 20, 2015 | Docket: 2658324

Published

determination of need and ability to pay: Section 61.13001(3)(e), Florida Statutes, expressly provides

In Re: Amendments to the Florida Supreme Court Approved Family Law Forms

173 So. 3d 19, 40 Fla. L. Weekly Supp. 163, 2015 Fla. LEXIS 583, 2015 WL 1343088

Supreme Court of Florida | Filed: Mar 26, 2015 | Docket: 2644899

Published

dependent or minor children and pursuant to Section 61.13001, Florida Statutes: 1. You plan to relocate

Vazquez v. Vazquez-Robelledo

150 So. 3d 855, 2014 Fla. App. LEXIS 18004, 2014 WL 5653398

District Court of Appeal of Florida | Filed: Nov 5, 2014 | Docket: 2592991

Published

ability to pay this “security deposit” and cites section 61.13001(6)(d), as authority for this provision. The

Justin Edward Johnson v. Samantha Nicole McCullough

143 So. 3d 1129, 2014 WL 3843082, 2014 Fla. App. LEXIS 12028

District Court of Appeal of Florida | Filed: Aug 6, 2014 | Docket: 843612

Published

applied to the statutory factors set forth in section 61.13001(7), Florida Statutes (2012), the court provided

Benjamin D. Rolison v. Rachel L. Rolison

144 So. 3d 610

District Court of Appeal of Florida | Filed: Aug 5, 2014 | Docket: 753784

Published

court’s order, which correctly found that section 61.13001, Florida Statutes (2013), Florida’s relocation

In Re: Amendments to the Florida Family Law Rules of Procedure New Rules for Qualified and Court-Appointed Parenting Coordinators

142 So. 3d 831, 39 Fla. L. Weekly Supp. 470, 2014 WL 3555960, 2014 Fla. LEXIS 2124

Supreme Court of Florida | Filed: Jul 3, 2014 | Docket: 58937

Published

approval or compliance with the requirements of section 61.13001, Florida Statutes. If the parenting coordinator

Kershaw v. Kershaw

141 So. 3d 642, 2014 WL 2740782, 2014 Fla. App. LEXIS 9209

District Court of Appeal of Florida | Filed: Jun 18, 2014 | Docket: 60241996

Published

so subject to the procedures set forth in section 61.13001, Florida Statutes (2018). Between June and

Albanese v. Albanese

135 So. 3d 532, 2014 WL 1325667, 2014 Fla. App. LEXIS 5012

District Court of Appeal of Florida | Filed: Apr 4, 2014 | Docket: 60239685

Published

would be in the best interest of the children. Section 61.13001(6)(b), Florida Statutes (2013), authorizes

Blakely v. Blakely

123 So. 3d 662, 2013 WL 5628682, 2013 Fla. App. LEXIS 16407

District Court of Appeal of Florida | Filed: Oct 16, 2013 | Docket: 60235149

Published

that the order is one for relocation under section 61.13001, Florida Statutes (2012), and hold that it

Fetzer v. Evans

123 So. 3d 124, 2013 WL 5575502, 2013 Fla. App. LEXIS 16186

District Court of Appeal of Florida | Filed: Oct 11, 2013 | Docket: 60234974

Published

petition to relocate the child pursuant to section 61.13001, Florida Statutes (2011). Former Husband filed

Marriage of Guizzardi v. Guizzardi

89 So. 3d 967, 2012 Fla. App. LEXIS 6837, 2012 WL 1520864

District Court of Appeal of Florida | Filed: May 2, 2012 | Docket: 60308862

Published

had satisfied the requirements imposed by section 61.13001(7) of the Florida Statutes and that she would

Alinat v. Curtis

86 So. 3d 552, 2012 WL 1366732, 2012 Fla. App. LEXIS 6171

District Court of Appeal of Florida | Filed: Apr 20, 2012 | Docket: 60307711

Published

law). We agree with the Former Husband that section 61.13001, Florida Statutes (2011), does not contemplate

McGrath v. Puckett

75 So. 3d 366, 2011 Fla. App. LEXIS 18604, 2011 WL 5843031

District Court of Appeal of Florida | Filed: Nov 22, 2011 | Docket: 60303716

Published

to an analysis of the factors set forth in section 61.13001, Florida Statutes. However, because the order

Wraight v. Wraight

71 So. 3d 139, 2011 Fla. App. LEXIS 13413, 2011 WL 3754715

District Court of Appeal of Florida | Filed: Aug 26, 2011 | Docket: 60302905

Published

and the factors relevant to relocation under section 61.13001, Florida Statutes. Husband complains that

VALQUI v. Rodriguez

75 So. 3d 751, 2011 Fla. App. LEXIS 13230, 2011 WL 3658389

District Court of Appeal of Florida | Filed: Aug 22, 2011 | Docket: 2359324

Published

an order like this one entered pursuant to Section 61.13001, Florida Statutes (2010), see Muller v. Muller

In Re Amend. to the Fla. Family Law Forms

59 So. 3d 792

Supreme Court of Florida | Filed: Dec 16, 2010 | Docket: 2361433

Published

to and must be sought in compliance with section 61.13001, Florida Statutes. XV. DISPUTES OR CONFLICT

In Re Amendments to the Florida Family Law Rules

55 So. 3d 381, 35 Fla. L. Weekly Supp. 524, 2010 Fla. LEXIS 1632, 2010 WL 3781979

Supreme Court of Florida | Filed: Sep 30, 2010 | Docket: 1931936

Published

legislative sessions, the Legislature amended section 61.13001, Florida Statutes, governing relocation. See

Tillotson v. Tillotson

32 So. 3d 191, 2010 Fla. App. LEXIS 4960, 2010 WL 1461575

District Court of Appeal of Florida | Filed: Apr 14, 2010 | Docket: 1662771

Published

intent to relocate with children" pursuant to section 61.13001(3), Florida Statutes (2008), and the matter

Zepeda v. Zepeda

32 So. 3d 679, 2010 Fla. App. LEXIS 3900, 35 Fla. L. Weekly Fed. D 699

District Court of Appeal of Florida | Filed: Mar 26, 2010 | Docket: 1662482

Published

permitting of relocation in a final judgment." § 61.13001(6)(b)(2), Fla. Stat. (2008). The factors to be

Porras v. Porras

29 So. 3d 1189, 2010 WL 838112

District Court of Appeal of Florida | Filed: Mar 12, 2010 | Docket: 1642940

Published

was filed.[1] Accordingly, as required by section 61.13001(3)(d), Florida Statutes (2009), the trial

Conners v. Mullins

27 So. 3d 199, 2010 Fla. App. LEXIS 1373, 2010 WL 445673

District Court of Appeal of Florida | Filed: Feb 10, 2010 | Docket: 2587611

Published

evaluating the child's best interests pursuant to section 61.13001(7), Florida Statutes, the trial court primarily

ARRABAL v. Hage

19 So. 3d 1137, 2009 Fla. App. LEXIS 15559, 2009 WL 3271343

District Court of Appeal of Florida | Filed: Oct 14, 2009 | Docket: 1164857

Published

legal merit. The notice of relocation statute, section 61.13001(3)(a), Florida Statutes (2008), applies to

A.V. v. M.G.

993 So. 2d 1140, 2008 Fla. App. LEXIS 16548

District Court of Appeal of Florida | Filed: Oct 31, 2008 | Docket: 64856341

Published

between the child and the nonrelocating parent.” § 61.13001(7)(c), Fla. Stat. (2006); see Fredman v. Fredman

Arthur v. Arthur

987 So. 2d 212, 2008 WL 2852873

District Court of Appeal of Florida | Filed: Jul 25, 2008 | Docket: 1723915

Published

submits that in analyzing the factors under section 61.13001, Florida Statutes (2006), which governs the

Sanchez v. Sanchez

958 So. 2d 1054, 2007 Fla. App. LEXIS 9143, 2007 WL 1687278

District Court of Appeal of Florida | Filed: Jun 13, 2007 | Docket: 64851110

Published

to address the statutory factors set out in section 61.13001(7), Florida Statutes (2006). We also are unable

Monasmith v. Monasmith

954 So. 2d 1271, 2007 Fla. App. LEXIS 6571, 2007 WL 1238706

District Court of Appeal of Florida | Filed: Apr 30, 2007 | Docket: 64850360

Published

We find that Appellant’s argument regarding section 61.13001, Florida Statutes (2006), was not preserved

Echezarreta v. Echezarreta

944 So. 2d 1169, 2006 WL 3615120

District Court of Appeal of Florida | Filed: Dec 13, 2006 | Docket: 1157121

Published

NOTES [1] Under the now-applicable statute, § 61.13001, Fla. Stat. (2006), which became effective on