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Florida Statute 61.14 - Full Text and Legal Analysis
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The 2025 Florida Statutes

Title VI
CIVIL PRACTICE AND PROCEDURE
Chapter 61
DISSOLUTION OF MARRIAGE; SUPPORT; TIME-SHARING
View Entire Chapter
F.S. 61.14
61.14 Enforcement and modification of support, maintenance, or alimony agreements or orders.—
(1)(a) When the parties enter into an agreement for payments for, or instead of, support, maintenance, or alimony, whether in connection with a proceeding for dissolution or separate maintenance or with any voluntary property settlement, or when a party is required by court order to make any payments, and the circumstances or the financial ability of either party changes or the child who is a beneficiary of an agreement or court order as described herein reaches majority after the execution of the agreement or the rendition of the order, either party may apply to the circuit court of the circuit in which the parties, or either of them, resided at the date of the execution of the agreement or reside at the date of the application, or in which the agreement was executed or in which the order was rendered, for an order decreasing or increasing the amount of support, maintenance, or alimony, and the court has jurisdiction to make orders as equity requires, with due regard to the changed circumstances or the financial ability of the parties or the child, decreasing, increasing, or confirming the amount of separate support, maintenance, or alimony provided for in the agreement or order. A finding that medical insurance is reasonably available or the child support guidelines schedule in s. 61.30 may constitute changed circumstances. Except as otherwise provided in s. 61.30(11)(c), the court may modify an order of support, maintenance, or alimony by increasing or decreasing the support, maintenance, or alimony retroactively to the date of the filing of the action or supplemental action for modification as equity requires, giving due regard to the changed circumstances or the financial ability of the parties or the child.
(b)1. The court must reduce or terminate an award of support, maintenance, or alimony upon specific written findings by the court that a supportive relationship has existed between the obligee and a person who is not related to the obligee by consanguinity or affinity.
2. In determining the nature of the relationship between an obligee and another person and the extent to which an award of support, maintenance, or alimony should be reduced or terminated because of the existence of a supportive relationship between an obligee and a person who is not related by consanguinity or affinity, the court shall make written findings of fact. The burden is on the obligor to prove, by a preponderance of the evidence, that a supportive relationship exists or has existed in the 365 days before the filing of the petition for dissolution of marriage, separate maintenance, or supplemental petition for modification. If a supportive relationship is proven to exist or to have existed, the burden shifts to the obligee to prove, by a preponderance of the evidence, that the court should not deny or reduce an initial award of support, maintenance, or alimony or reduce or terminate an existing award of support, maintenance, or alimony. The court shall consider and make written findings of fact regarding all relevant facts in s. 61.08(3) and the following additional factors:
a. The extent to which the obligee and the other person have held themselves out as a married couple by engaging in conduct such as using the same last name, using a common mailing address, referring to each other in terms such as “my husband” or “my wife,” or otherwise conducting themselves in a manner that evidences a permanent supportive relationship.
b. The period of time that the obligee has resided with the other person.
c. The extent to which the obligee and the other person have pooled their assets or income, acquired or maintained a joint bank account or other financial accounts, or otherwise exhibited financial interdependence.
d. The extent to which the obligee or the other person has financially supported the other, in whole or in part, including payment of the other’s debts, expenses, or liabilities.
e. The extent to which the obligee or the other person has performed valuable services for the other.
f. The extent to which the obligee or the other person has performed valuable services for the other’s business entity or employer.
g. The extent to which the obligee and the other person have worked together to acquire any assets or to enhance the value of any assets.
h. The extent to which the obligee and the other person have jointly contributed to the purchase of any real or personal property.
i. The extent to which the obligee and the other person have an express or implied agreement regarding property sharing or financial support.
j. The extent to which the obligor has paid the existing alimony award or failed to do so and the existence and amount of any arrearage.
k. The extent to which the obligee and the other person have provided support to the children or other family members of one another, regardless of any legal duty to do so.
3. This paragraph does not abrogate the requirement that every marriage in this state be solemnized under a license, does not recognize a common law marriage as valid, and does not recognize a de facto marriage. This paragraph recognizes that relationships exist that provide financial or economic support equivalent to a marriage and that support, maintenance, or alimony must be modified or terminated if such a relationship is proven to exist. The existence of a conjugal relationship is not necessary for the application of this paragraph.
(c)1. The court may reduce or terminate an award of support, maintenance, or alimony upon specific, written findings of fact that the obligor has reached normal retirement age as defined by the Social Security Administration or the customary retirement age for his or her profession and that the obligor has taken demonstrative and measurable efforts or actions to retire or has actually retired. The burden is on the obligor to prove, by a preponderance of the evidence, that his or her retirement reduces his or her ability to pay support, maintenance, or alimony. If the court determines that the obligor’s retirement has reduced or will reduce the obligor’s ability to pay, the burden shifts to the obligee to prove, by a preponderance of the evidence, that the obligor’s support, maintenance, or alimony obligation should not be terminated or reduced.
2. In determining whether an award of support, maintenance, or alimony should be reduced or terminated because of the obligor’s voluntary retirement, the court shall give consideration to, and make written findings of fact regarding the following factors:
a. The age and health of the obligor.
b. The nature and type of work performed by the obligor.
c. The customary age of retirement in the obligor’s profession.
d. The obligor’s motivation for retirement and likelihood of returning to work.
e. The needs of the obligee and the ability of the obligee to contribute toward his or her own basic needs.
f. The economic impact that a termination or reduction of alimony would have on the obligee.
g. All assets of the obligee and the obligor accumulated or acquired prior to the marriage, during the marriage, or following the entry of the final judgment as well as the obligor and obligee’s respective roles in the wasteful depletion of any marital assets received by him or her at the time of the entry of the final judgment.
h. The income of the obligee and the obligor earned during the marriage or following the entry of the final judgment.
i. The social security benefits, retirement plan benefits, or pension benefits payable to the obligor and the obligee following the final judgment of dissolution.
j. The obligor’s compliance, in whole or in part, with the existing alimony obligation.
3. In reasonable anticipation of retirement, but not more than 6 months before retirement, the obligor may file a petition for modification of his or her support, maintenance, or alimony obligation, which shall be effective upon his or her reasonable and voluntary retirement as determined by the court pursuant to the factors in subparagraph 2. The court shall give consideration to, and make written findings of fact regarding, the factors in subparagraph 2. and s. 61.08(3) when granting or denying the obligor’s petition for modification; when confirming, reducing, or terminating the obligor’s alimony obligation; and when granting or denying any request for modification, the date of filing of the obligor’s modification petition, or other date post-filing as equity requires, giving due regard and consideration to the changed circumstances or the financial ability of the parties.
(d) For each support order reviewed by the department as required by s. 409.2564(11), if the amount of the child support award under the order differs by at least 10 percent but not less than $25 from the amount that would be awarded under s. 61.30, the department shall seek to have the order modified and any modification shall be made without a requirement for proof or showing of a change in circumstances.
(e) The department shall have authority to adopt rules to implement this section.
(2) When an order or agreement is modified pursuant to subsection (1), the party having an obligation to pay shall pay only the amount of support, maintenance, or alimony directed in the new order, and the agreement or earlier order is modified accordingly. No person may commence an action for modification of a support, maintenance, or alimony agreement or order except as herein provided. No court has jurisdiction to entertain any action to enforce the recovery of separate support, maintenance, or alimony other than as herein provided.
(3) This section is declaratory of existing public policy and of the laws of this state.
(4) If a party applies for a reduction of alimony or child support and the circumstances justify the reduction, the court may make the reduction of alimony or child support regardless of whether or not the party applying for it has fully paid the accrued obligations to the other party at the time of the application or at the time of the order of modification.
(5)(a) When a court of competent jurisdiction enters an order for the payment of alimony or child support or both, the court shall make a finding of the obligor’s imputed or actual present ability to comply with the order. If the obligor subsequently fails to pay alimony or support and a contempt hearing is held, the original order of the court creates a presumption that the obligor has the present ability to pay the alimony or support and to purge himself or herself from the contempt. At the contempt hearing, the obligor shall have the burden of proof to show that he or she lacks the ability to purge himself or herself from the contempt. This presumption is adopted as a presumption under s. 90.302(2) to implement the public policy of this state that children shall be maintained from the resources of their parents and as provided for in s. 409.2551, and that spouses be maintained as provided for in s. 61.08. The court shall state in its order the reasons for granting or denying the contempt.
(b) In a proceeding in circuit court to enforce a support order under this chapter, chapter 88, chapter 409, or chapter 742, or any other provision of law, if the court finds that payments due under the support order are delinquent or overdue and that the obligor is unemployed, underemployed, or has no income but is able to work or participate in job training, the court may order the obligor to:
1. Seek employment.
2. File periodic reports with the court, or with the department if the department is providing Title IV-D services, detailing the obligor’s efforts to seek and obtain employment during the reporting period.
3. Notify the court or the department, as appropriate, upon obtaining employment, income, or property.
4. Participate in job training, job placement, work experience, or other work programs that may be available pursuant to chapter 445, chapter 446, or any other source.

An obligor who willfully fails to comply with a court order to seek work or participate in other work-related activities may be held in contempt of court. This paragraph is in furtherance of the public policy of the state of ensuring that children are maintained from the resources of their parents to the extent possible.

(6)(a)1. When support payments are made through the local depository or through the State Disbursement Unit, any payment or installment of support which becomes due and is unpaid under any support order is delinquent; and this unpaid payment or installment, and all other costs and fees herein provided for, become, after notice to the obligor and the time for response as set forth in this subsection, a final judgment by operation of law, which has the full force, effect, and attributes of a judgment entered by a court in this state for which execution may issue. No deduction shall be made by the local depository from any payment made for costs and fees accrued in the judgment by operation of law process under paragraph (b) until the total amount of support payments due the obligee under the judgment has been paid.
2. A certified statement by the local depository evidencing a delinquency in support payments constitute evidence of the final judgment under this paragraph.
3. The judgment under this paragraph is a final judgment as to any unpaid payment or installment of support which has accrued up to the time either party files a motion with the court to alter or modify the support order, and such judgment may not be modified by the court. The court may modify such judgment as to any unpaid payment or installment of support which accrues after the date of the filing of the motion to alter or modify the support order. This subparagraph does not prohibit the court from providing relief from the judgment pursuant to Rule 1.540, Florida Rules of Civil Procedure.
(b)1. When an obligor is 15 days delinquent in making a payment or installment of support and the amount of the delinquency is greater than the periodic payment amount ordered by the court, the local depository shall serve notice on the obligor informing him or her of:
a. The delinquency and its amount.
b. An impending judgment by operation of law against him or her in the amount of the delinquency and all other amounts which thereafter become due and are unpaid, together with costs and a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, for failure to pay the amount of the delinquency.
c. The obligor’s right to contest the impending judgment and the ground upon which such contest can be made.
d. The local depository’s authority to release information regarding the delinquency to one or more credit reporting agencies.
2. The local depository shall serve the notice by mailing it by first-class mail to the obligor at his or her last address of record with the local depository. If the obligor has no address of record with the local depository, service shall be by publication as provided in chapter 49.
3. When service of the notice is made by mail, service is complete on the date of mailing.
(c) Within 15 days after service of the notice is complete, the obligor may file with the court that issued the support order, or with the court in the circuit where the local depository which served the notice is located, a motion to contest the impending judgment. An obligor may contest the impending judgment only on the ground of a mistake of fact regarding an error in whether a delinquency exists, in the amount of the delinquency, or in the identity of the obligor.
(d) The court shall hear the obligor’s motion to contest the impending judgment within 15 days after the date of filing of the motion. Upon the court’s denial of the obligor’s motion, the amount of the delinquency and all other amounts that become due, together with costs and a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, become a final judgment by operation of law against the obligor. The depository shall charge interest at the rate established in s. 55.03 on all judgments for support. Payments on judgments shall be applied first to the current child support due, then to any delinquent principal, and then to interest on the support judgment.
(e) If the obligor fails to file a motion to contest the impending judgment within the time limit prescribed in paragraph (c) and fails to pay the amount of the delinquency and all other amounts which thereafter become due, together with costs and a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, such amounts become a final judgment by operation of law against the obligor at the expiration of the time for filing a motion to contest the impending judgment.
(f)1. Upon request of any person, the local depository shall issue, upon payment of a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, a payoff statement of the total amount due under the judgment at the time of the request. The statement may be relied upon by the person for up to 30 days from the time it is issued unless proof of satisfaction of the judgment is provided.
2. When the depository records show that the obligor’s account is current, the depository shall record a satisfaction of the judgment upon request of any interested person and upon receipt of the appropriate recording fee. Any person shall be entitled to rely upon the recording of the satisfaction.
3. The local depository, at the direction of the department, or the obligee in a non-IV-D case, may partially release the judgment as to specific real property, and the depository shall record a partial release upon receipt of the appropriate recording fee.
4. The local depository is not liable for errors in its recordkeeping, except when an error is a result of unlawful activity or gross negligence by the clerk or his or her employees.
(g) The local depository shall send the department monthly by electronic means a list of all Title IV-D and non-Title IV-D cases in which a judgment by operation of law has been recorded during the month for which the data is provided. At a minimum, the depository shall provide the names of the obligor and obligee, social security numbers of the obligor and obligee, if available, and depository number.
(7) When modification of an existing order of support is sought, the proof required to modify a settlement agreement and the proof required to modify an award established by court order shall be the same.
(8)(a) When an employee and an employer reach an agreement for a lump-sum settlement under s. 440.20(11), no proceeds of the settlement shall be disbursed to the employee, nor shall any attorney’s fees be disbursed, until after a judge of compensation claims reviews the proposed disbursement and enters an order finding the settlement provides for appropriate recovery of any support arrearage. The employee, or the employee’s attorney if the employee is represented, shall submit a written statement from the department that indicates whether the employee owes unpaid support and, if so, the amount owed. In addition, the judge of compensation claims may require the employee to submit a similar statement from a local depository established under s. 61.181. A sworn statement by the employee that all existing support obligations have been disclosed is also required. If the judge finds the proposed allocation of support recovery insufficient, the parties may amend the allocation of support recovery within the settlement agreement to make the allocation of proceeds sufficient. The Office of the Judges of Compensation Claims shall adopt procedural rules to implement this paragraph.
(b) In accordance with the provisions of s. 440.22, any compensation due or that may become due an employee under chapter 440 is exempt from garnishment, attachment, execution, and assignment of income, except for the purposes of enforcing child or spousal support obligations.
(9) Unless otherwise ordered by the court or agreed to by the parties, the obligation to pay the current child support for that child is terminated when the child reaches 18 years of age or the disability of nonage is removed. The termination of the current child support obligation does not otherwise terminate the obligation to pay any arrearage, retroactive support, delinquency, or costs owed by the obligor.
(10)(a) In a Title IV-D case, if an obligation to pay current child support is terminated due to the emancipation of the child and the obligor owes an arrearage, retroactive support, delinquency, or costs, the obligor shall continue to pay at the same rate in effect immediately prior to emancipation until all arrearages, retroactive support, delinquencies, and costs are paid in full or until the amount of the order is modified. Any income-deducted amount or amount paid by the obligor which is in excess of the obligation to pay current support shall be credited against the arrearages, retroactive support, delinquency, and costs owed by the obligor.
(b) In a Title IV-D case, if an obligation to pay current child support for multiple children is reduced due to the emancipation of one child and the obligor owes an arrearage, retroactive support, delinquency, or costs, the obligor shall continue to pay at the same rate in effect immediately prior to emancipation until all arrearages, retroactive support, delinquencies, and costs are paid in full or until the amount of the order is modified. Any income-deducted amount or amount paid by the obligor which is in excess of the obligation to pay current support shall be credited against the arrearages, retroactive support, delinquency, and costs owed by the obligor. If an obligation to pay current support for more than one child is not reduced when a child is emancipated because the order does not allocate support per child, this paragraph does not apply.
(c) Paragraphs (a) and (b) provide an additional remedy for collection of unpaid support and apply to cases in which a support order was entered before, on, or after July 1, 2004.
(11)(a) A court may, upon good cause shown, and without a showing of a substantial change of circumstances, modify, vacate, or set aside a temporary support order before or upon entering a final order in a proceeding.
(b) The modification of the temporary support order may be retroactive to the date of the initial entry of the temporary support order; to the date of filing of the initial petition for dissolution of marriage, initial petition for support, initial petition determining paternity, or supplemental petition for modification; or to a date prescribed in paragraph (1)(a) or s. 61.30(11)(c) or (17), as applicable.
History.—ss. 1, 2, ch. 16780, 1935; CGL 1936 Supp. 4993(1); s. 16, ch. 67-254; s. 16, ch. 71-241; s. 2, ch. 75-67; s. 124, ch. 86-220; s. 5, ch. 87-95; s. 6, ch. 88-176; s. 14, ch. 91-45; s. 5, ch. 92-138; s. 3, ch. 93-208; s. 335, ch. 95-147; s. 15, ch. 95-222; s. 7, ch. 97-170; s. 40, ch. 98-397; s. 5, ch. 99-375; s. 1, ch. 2001-91; ss. 10, 11, ch. 2001-158; s. 3, ch. 2002-173; s. 73, ch. 2003-402; s. 1, ch. 2004-47; s. 50, ch. 2004-265; s. 4, ch. 2004-334; ss. 5, 6, 7, 8, ch. 2005-39; s. 3, ch. 2005-82; s. 1, ch. 2005-168; s. 11, ch. 2008-61; s. 1, ch. 2008-92; s. 28, ch. 2008-111; s. 16, ch. 2010-187; s. 14, ch. 2019-58; s. 3, ch. 2023-315.
Note.—Former s. 65.15.

F.S. 61.14 on Google Scholar

F.S. 61.14 on CourtListener

Amendments to 61.14


Annotations, Discussions, Cases:

Cases Citing Statute 61.14

Total Results: 511

In Re Montgomery Hulon Harrell, Debtor, Montgomery Hulon Harrell v. Caryl Ann (Kaldenberg) Harrell Sharp

754 F.2d 902, 12 Collier Bankr. Cas. 2d 340, 1985 U.S. App. LEXIS 28241, 12 Bankr. Ct. Dec. (CRR) 1328

Court of Appeals for the Eleventh Circuit | Filed: Mar 4, 1985 | Docket: 260514

Cited 198 times | Published

-27 (Michie 1982 & Supp. 1984); Fla.Stat.Ann. § 61.14 (West Supp.1984); McGugin v. McGugin,

Pimm v. Pimm

601 So. 2d 534, 1992 WL 110896

Supreme Court of Florida | Filed: May 28, 1992 | Docket: 1305335

Cited 77 times | Published

Chastain v. Chastain, 73 So.2d 66 (Fla. 1954); § 61.14(1), Fla. Stat. (Supp. 1988). Second, the change

Pompey v. Broward County

95 F.3d 1543, 1996 U.S. App. LEXIS 25009, 1996 WL 514879

Court of Appeals for the Eleventh Circuit | Filed: Sep 26, 1996 | Docket: 1118660

Cited 70 times | Published

to spend on each case, see, e.g., Fla.Stat.Ann. § 61.14(5) (West 1988 & Supp.1996); Fla.R.Jud.Admin., Rule

Firestone v. Firestone

263 So. 2d 223

Supreme Court of Florida | Filed: Apr 12, 1972 | Docket: 2467363

Cited 62 times | Published

merits of this issue. See also Florida Statute § 61.14. Therefore, the chancellor may want to examine

Posner v. Posner

233 So. 2d 381

Supreme Court of Florida | Filed: Mar 25, 1970 | Docket: 1767139

Cited 62 times | Published

alimony and/or property rights of the parties. Section 61.14, Florida Statutes, F.S.A. (Ch. 16780, 1935)

Belcher v. Belcher

271 So. 2d 7

Supreme Court of Florida | Filed: Aug 23, 1972 | Docket: 1438680

Cited 53 times | Published

decreased under changed conditions as provided for in § 61.14, Florida Statutes, F.S.A.' The decision in that

Walter v. Walter

464 So. 2d 538, 10 Fla. L. Weekly 118

Supreme Court of Florida | Filed: Feb 14, 1985 | Docket: 1661400

Cited 45 times | Published

substantial and material change of circumstances under F.S. 61.14, 1982 as amended. (Emphasis added.) In reviewing

Posner v. Posner

257 So. 2d 530

Supreme Court of Florida | Filed: Mar 8, 1972 | Docket: 1287294

Cited 38 times | Published

antenuptial agreement is controlled by Florida Statutes § 61.14, F.S.A., which provides that when "the circumstances

Lang v. Lang

252 So. 2d 809

District Court of Appeal of Florida | Filed: Sep 28, 1971 | Docket: 1274562

Cited 32 times | Published

this proposition the legislature enacted F.S. Section 61.14, F.S.A., which permits either party to apply

Lee v. Lee

309 So. 2d 26

District Court of Appeal of Florida | Filed: Mar 5, 1975 | Docket: 1770618

Cited 31 times | Published

1973. [4] Cf. Lash v. Lash, n. 1 supra. [5] Section 61.14, F.S. 1973. Also cf. Cantor v. Cantor (Fla.App

Pompey v. Cochran

685 So. 2d 1007, 1997 WL 4765

District Court of Appeal of Florida | Filed: Jan 8, 1997 | Docket: 1735185

Cited 30 times | Published

on an issue not addressed by the majority, section 61.14(5), Florida Statutes. The statute creates a

Overbey v. Overbey

698 So. 2d 811, 1997 WL 296971

Supreme Court of Florida | Filed: Jun 5, 1997 | Docket: 434865

Cited 28 times | Published

resolve the issue presented by these cases. Section 61.14(1), Florida Statutes (1995), governs "[e]nforcement

Meltzer v. Meltzer

356 So. 2d 1263

District Court of Appeal of Florida | Filed: Mar 7, 1978 | Docket: 1478504

Cited 28 times | Published

v. Brown, 315 So.2d 15 (Fla. 3d DCA 1975), Section 61.14 Florida Statutes (1975). We are persuaded that

Pastore v. Pastore

497 So. 2d 635, 11 Fla. L. Weekly 495

Supreme Court of Florida | Filed: Sep 25, 1986 | Docket: 1689667

Cited 27 times | Published

she may seek a modification of alimony under section 61.14, Florida Statutes (1985). At the moment, however

Desilets v. Desilets

377 So. 2d 761

District Court of Appeal of Florida | Filed: Nov 30, 1979 | Docket: 423294

Cited 27 times | Published

ability of either the husband or the wife. Section 61.14, Florida Statutes (1977); Brown v. Brown, 315

De Cenzo v. De Cenzo

433 So. 2d 1316

District Court of Appeal of Florida | Filed: Jul 5, 1983 | Docket: 1727380

Cited 26 times | Published

circumstances before a modification will be allowed. Section 61.14, Florida Statutes (1981); Holland v. Holland

Jaffee v. Jaffee

394 So. 2d 443

District Court of Appeal of Florida | Filed: Feb 3, 1981 | Docket: 1315378

Cited 25 times | Published

subject to modification upon a proper showing, § 61.14, Fla. Stat. (1977),[4] the grounds relied upon

Rosen v. Rosen

386 So. 2d 1268

District Court of Appeal of Florida | Filed: Aug 5, 1980 | Docket: 1518305

Cited 21 times | Published

Adams, supra. It may also be modified under Section 61.14, Florida Statutes (1979). By successfully challenging

Scott v. Scott

285 So. 2d 423

District Court of Appeal of Florida | Filed: Nov 2, 1973 | Docket: 1491143

Cited 21 times | Published

filed his petition for modification under F.S. § 61.14, F.S.A. 1971. At the hearing on said petition both

Sistrunk v. Sistrunk

235 So. 2d 53

District Court of Appeal of Florida | Filed: May 8, 1970 | Docket: 1382795

Cited 21 times | Published

final judgment allowing alimony to the wife (Section 61.14, F.S. 1967, F.S.A.), there is no statutory authority

Acker v. Acker

904 So. 2d 384, 2005 WL 851010

Supreme Court of Florida | Filed: Apr 14, 2005 | Docket: 103498

Cited 20 times | Published

be made in accordance with section 61.08(2). Section 61.14 itself provides no criteria on which to make

McNaughton v. McNaughton

332 So. 2d 673

District Court of Appeal of Florida | Filed: May 11, 1976 | Docket: 1691812

Cited 20 times | Published

circumstances or where equity so requires. See Fla. Stat. § 61.14; and Nichols v. Nichols, Fla.App. 1974, 304 So

Woolf v. Woolf

901 So. 2d 905, 2005 WL 906191

District Court of Appeal of Florida | Filed: Apr 20, 2005 | Docket: 1666215

Cited 19 times | Published

382 So.2d 1197, 1201 (Fla.1980). Florida Statute § 61.14 (2004), governs the modification of alimony. It

Woolf v. Woolf

901 So. 2d 905, 2005 WL 906191

District Court of Appeal of Florida | Filed: Apr 20, 2005 | Docket: 1666215

Cited 19 times | Published

382 So.2d 1197, 1201 (Fla.1980). Florida Statute § 61.14 (2004), governs the modification of alimony. It

Brisco v. Brisco

355 So. 2d 506

District Court of Appeal of Florida | Filed: Mar 3, 1978 | Docket: 1360872

Cited 19 times | Published

that Section 61.14, Florida Statutes (1975) is applicable to the litigation herein. Section 61.14(1),

Brisco v. Brisco

355 So. 2d 506

District Court of Appeal of Florida | Filed: Mar 3, 1978 | Docket: 1360872

Cited 19 times | Published

that Section 61.14, Florida Statutes (1975) is applicable to the litigation herein. Section 61.14(1),

Burkley v. Burkley

911 So. 2d 262, 2005 WL 2396501

District Court of Appeal of Florida | Filed: Sep 30, 2005 | Docket: 1501217

Cited 18 times | Published

or when he entered the VA Program in 2002. Section 61.14(1)(a) expressly delineates the court's power

Braswell v. Braswell

881 So. 2d 1193, 2004 WL 2049978

District Court of Appeal of Florida | Filed: Sep 15, 2004 | Docket: 2547873

Cited 18 times | Published

characteristics to consider. For instance, according to section 61.14, Florida Statutes (2001), a support award is

Bedell v. Bedell

583 So. 2d 1005, 1991 WL 88741

Supreme Court of Florida | Filed: May 30, 1991 | Docket: 1684140

Cited 18 times | Published

Appeal rejected the wife's contention that under section 61.14(1), Florida Statutes (1985), she was entitled

Brown v. Brown

315 So. 2d 15

District Court of Appeal of Florida | Filed: May 27, 1975 | Docket: 2505094

Cited 18 times | Published

Chastain v. Chastain, Fla. 1954, 73 So.2d 66; § 61.14(1), Fla. Stat. We have examined and assessed the

Bernstein v. Bernstein

498 So. 2d 1270, 11 Fla. L. Weekly 2212

District Court of Appeal of Florida | Filed: Oct 15, 1986 | Docket: 1334971

Cited 17 times | Published

settlement agreement. The pertinent subparagraph of section 61.14, Florida Statutes (1985), provides: (1) When

Garrison v. Garrison

380 So. 2d 473

District Court of Appeal of Florida | Filed: Feb 6, 1980 | Docket: 1402848

Cited 17 times | Published

circumstances or where equity so requires. See Fla. Stat. § 61.14; and Nichols v. Nichols, Fla.App. 1974, 304 So

Smith v. Smith

378 So. 2d 11

District Court of Appeal of Florida | Filed: Nov 20, 1979 | Docket: 1794887

Cited 17 times | Published

subject to modification upon a proper showing, under § 61.14, F.S. (1975) of a change in the wife's circumstances

Donoff v. Donoff

940 So. 2d 1221, 2006 WL 3077748

District Court of Appeal of Florida | Filed: Nov 1, 2006 | Docket: 433978

Cited 16 times | Published

economic factors" when modifying alimony under section 61.14. Indeed section 61.08(2) specifies that it applies

Turner v. Turner

383 So. 2d 700

District Court of Appeal of Florida | Filed: Apr 30, 1980 | Docket: 1395997

Cited 16 times | Published

Estoppel and Waiver § 5. Subsection (3) of Section 61.14, Florida Statutes (1979) provides: This section

Pfohl v. Pfohl

345 So. 2d 371

District Court of Appeal of Florida | Filed: Apr 26, 1977 | Docket: 1478063

Cited 16 times | Published

court for modification of the alimony award. Section 61.14 Florida Statutes (1975); Lee v. Lee, 309 So

Hirsch v. Hirsch

309 So. 2d 47

District Court of Appeal of Florida | Filed: Feb 18, 1975 | Docket: 1033730

Cited 16 times | Published

separation agreement is answered by a review of § 61.14, Fla. Stat., which provides in pertinent part that

Schwartz v. Schwartz

297 So. 2d 117

District Court of Appeal of Florida | Filed: Jun 18, 1974 | Docket: 450958

Cited 16 times | Published

as provided for by proceedings brought under § 61.14 Fla. Stat., F.S.A. The judgment as amended is affirmed

Mills v. Mills

339 So. 2d 681

District Court of Appeal of Florida | Filed: Nov 17, 1976 | Docket: 1729534

Cited 15 times | Published

modification of the alimony payments under Section 61.14, Florida Statutes (1975), yet it is obvious

Wilson v. Wilson

279 So. 2d 893

District Court of Appeal of Florida | Filed: Jun 22, 1973 | Docket: 1522142

Cited 15 times | Published

trial court review of the award and relief. Section 61.14, F.S. 1971, F.S.A. To highlight the inequity

Ghay v. Ghay

954 So. 2d 1186, 2007 WL 1094304

District Court of Appeal of Florida | Filed: Apr 13, 2007 | Docket: 1165388

Cited 14 times | Published

circuit court while the litigation proceeds. See § 61.14(11), Fla. Stat. (2005).[3] If further discovery

Department of Revenue v. Jackson

846 So. 2d 486, 2003 WL 1922661

Supreme Court of Florida | Filed: Apr 24, 2003 | Docket: 1709864

Cited 14 times | Published

parties. See § 61.13(1)(a), Fla. Stat. (2001). Section 61.14, Florida Statutes (2001), contemplates that

Pujals v. Pujals

414 So. 2d 228

District Court of Appeal of Florida | Filed: May 4, 1982 | Docket: 1707044

Cited 14 times | Published

rehabilitation provided by the final judgment. Section 61.14, Fla. Stat. (1979);[4]Myrick v. Myrick, 402

Hurtado v. Hurtado

407 So. 2d 627

District Court of Appeal of Florida | Filed: Nov 25, 1981 | Docket: 467486

Cited 14 times | Published

case, modification of alimony judgments (Florida Statute 61.14)." Similarly, in Bender v. Bender, 363 So

Powell v. Powell

386 So. 2d 1214

District Court of Appeal of Florida | Filed: Jul 1, 1980 | Docket: 477293

Cited 14 times | Published

agreement between the parties.[2] We affirm. Under Section 61.14, Florida Statutes (1977) and the established

Bailey v. Bailey

300 So. 2d 294

District Court of Appeal of Florida | Filed: Sep 20, 1974 | Docket: 1434945

Cited 14 times | Published

trial court only *296 upon a showing under Section 61.14, F.S. of a change of circumstances subsequent

Waugh v. Waugh

679 So. 2d 1, 1996 WL 170181

District Court of Appeal of Florida | Filed: Apr 12, 1996 | Docket: 1215113

Cited 13 times | Published

of a present ability to pay as required by section 61.14(5)(a), Florida Statutes (1993), which provides:

Johnson v. Johnson

403 So. 2d 1388

District Court of Appeal of Florida | Filed: Oct 7, 1981 | Docket: 1251027

Cited 13 times | Published

Ohmes v. Ohmes, 200 So.2d 849 (Fla. 2d DCA 1967); § 61.14, Fla. Stat. (1979). *1391 We must now address the

Nicolay v. Nicolay

387 So. 2d 500

District Court of Appeal of Florida | Filed: Aug 27, 1980 | Docket: 1355833

Cited 13 times | Published

continued ability to pay. Canakaris v. Canakaris; § 61.14, Fla. Stat. (1979). Applying these rules to the

Burdack v. Burdack

371 So. 2d 528

District Court of Appeal of Florida | Filed: May 25, 1979 | Docket: 1785821

Cited 13 times | Published

the agreement of the parties is authorized by Section 61.14(1), Florida Statutes (1977). A fundamental prerequisite

Ruhnau v. Ruhnau

299 So. 2d 61

District Court of Appeal of Florida | Filed: Aug 27, 1974 | Docket: 1745581

Cited 13 times | Published

case, modification of alimony judgments (Florida Statute 61.14). Needless to say, awards of alimony may

First National Bank of St. Petersburg v. Ford

283 So. 2d 342

Supreme Court of Florida | Filed: Sep 28, 1973 | Docket: 1489742

Cited 13 times | Published

agreements as provided by Florida Statutes, Section 61.14,[1] F.S.A. (previously Florida Statutes, Section

First National Bank of St. Petersburg v. Ford

283 So. 2d 342

Supreme Court of Florida | Filed: Sep 28, 1973 | Docket: 1489742

Cited 13 times | Published

agreements as provided by Florida Statutes, Section 61.14,[1] F.S.A. (previously Florida Statutes, Section

State Ex Rel. Pittman v. Stanjeski

562 So. 2d 673, 1990 WL 68089

Supreme Court of Florida | Filed: May 17, 1990 | Docket: 1256049

Cited 12 times | Published

the district courts declared unconstitutional section 61.14(5), Florida Statutes (1987). The statute, as

Diaco v. Diaco

363 So. 2d 183

District Court of Appeal of Florida | Filed: Oct 11, 1978 | Docket: 461014

Cited 12 times | Published

v. Lee, 157 Fla. 439, 26 So.2d 177 (1946); Section 61.14, Florida Statutes (1977). The burden of proving

Sheffield v. Sheffield

310 So. 2d 410

District Court of Appeal of Florida | Filed: Mar 11, 1975 | Docket: 1281429

Cited 12 times | Published

on the basis of a "de facto" marriage. However, § 61.14, Fla. Stat., provides that alimony and property

Sherman v. Sherman

279 So. 2d 887

District Court of Appeal of Florida | Filed: Jun 26, 1973 | Docket: 425428

Cited 12 times | Published

in the affirmative upon authority of Fla. Stat. § 61.14(1), F.S.A., which provides in part: "* * * when

Carmel v. Carmel

282 So. 2d 6

District Court of Appeal of Florida | Filed: Jun 26, 1973 | Docket: 1235450

Cited 12 times | Published

appellant-wife on the sole basis of her employment. F.S. § 61.14 F.S.A., which was correctly relied upon by the

Keller v. Belcher

256 So. 2d 561

District Court of Appeal of Florida | Filed: Dec 7, 1971 | Docket: 427697

Cited 12 times | Published

to the motion, Henry alleged that § 61.08 and § 61.14, Fla. Stat., F.S.A., as applied, violated certain

Buxton v. Buxton

963 So. 2d 950, 2007 WL 2481667

District Court of Appeal of Florida | Filed: Sep 5, 2007 | Docket: 1328295

Cited 11 times | Published

"supportive relationship" as that phrase is used in section 61.14(1)(b), Florida Statutes (2005). Because the

Hannon v. Hannon

740 So. 2d 1181, 1999 WL 346110

District Court of Appeal of Florida | Filed: Jun 2, 1999 | Docket: 1746380

Cited 11 times | Published

JJ., concur. KLEIN, J., recused. NOTES [1] See § 61.14(1), Fla. Stat. (1997) (alimony generally modifiable

Mascola v. Lusskin

727 So. 2d 328, 1999 WL 71667

District Court of Appeal of Florida | Filed: Feb 17, 1999 | Docket: 1438298

Cited 11 times | Published

are covered by the basic rules of fairness. See § 61.14(1) ("court has jurisdiction to make orders as equity

Stewart v. Rich

664 So. 2d 1145, 1995 WL 749632

District Court of Appeal of Florida | Filed: Dec 20, 1995 | Docket: 1386714

Cited 11 times | Published

Chastain v. Chastain, 73 So.2d 66 (Fla. 1954); § 61.14(1), Fla. Stat. (Supp. 1988). Second, the change

Atkins v. Atkins

611 So. 2d 570, 1992 WL 387437

District Court of Appeal of Florida | Filed: Dec 31, 1992 | Docket: 1757338

Cited 11 times | Published

seeking a modification of an alimony award. Section 61.14, Florida Statutes (1989); Zipperer v. Zipperer

Greene v. Greene

547 So. 2d 1302, 1989 WL 100493

District Court of Appeal of Florida | Filed: Sep 1, 1989 | Docket: 1738700

Cited 11 times | Published

enough to encompass a modification as well. See § 61.14(1), Fla. Stat. (1987). Reversed and remanded. SCHEB

Wanstall v. Wanstall

427 So. 2d 353

District Court of Appeal of Florida | Filed: Mar 2, 1983 | Docket: 1648100

Cited 11 times | Published

by the court. § 61.13, Fla. Stat. (1981).[1] Section 61.14, Florida Statutes (1981),[2] specifically provides

Wolfe v. Wolfe

424 So. 2d 32

District Court of Appeal of Florida | Filed: Nov 24, 1982 | Docket: 437010

Cited 11 times | Published

two concepts is determinative. Pursuant to section 61.14(1), Florida Statutes (1973), payments that are

Lacy v. Lacy

413 So. 2d 472

District Court of Appeal of Florida | Filed: May 5, 1982 | Docket: 1345145

Cited 11 times | Published

agreement into the dissolution judgment.[1] Second, section 61.14(1), Florida Statutes (1981), specifically addresses

Woodworth v. Woodworth

385 So. 2d 1024

District Court of Appeal of Florida | Filed: May 21, 1980 | Docket: 1337343

Cited 11 times | Published

increasing the amount provided for in the agreement. Section 61.14, Florida Statutes (1975). On the other hand

Pullo v. Pullo

926 So. 2d 448, 2006 WL 941914

District Court of Appeal of Florida | Filed: Apr 13, 2006 | Docket: 1515291

Cited 10 times | Published

property. Florida courts uniformly agree that section 61.14(1), Florida Statutes, does not allow modification

Schneider v. Schneider

467 So. 2d 465, 10 Fla. L. Weekly 1004

District Court of Appeal of Florida | Filed: Apr 18, 1985 | Docket: 1680556

Cited 10 times | Published

The test for modification is set forth in section 61.14, Florida Statutes (1983), viz: a change in circumstances

Bowen v. Bowen

347 So. 2d 675

District Court of Appeal of Florida | Filed: Jun 7, 1977 | Docket: 224191

Cited 10 times | Published

upon a change in circumstances pursuant to Section 61.14, Florida Statutes (1975). The wife shall be

Anderson v. Anderson

333 So. 2d 484

District Court of Appeal of Florida | Filed: May 25, 1976 | Docket: 2306806

Cited 10 times | Published

for further modification of the judgment under § 61.14 Fla. Stat., F.S.A. to require payment of some alimony

Goldstein v. Goldstein

310 So. 2d 361

District Court of Appeal of Florida | Filed: Mar 18, 1975 | Docket: 1281463

Cited 10 times | Published

trial court review of the award and relief. Section 61.14, F.S. 1971, F.S.A." In Schwartz v. Schwartz

Feder v. Feder

291 So. 2d 641

District Court of Appeal of Florida | Filed: Mar 5, 1974 | Docket: 1351191

Cited 10 times | Published

petition for modification of the judgment under § 61.14 Fla. Stat., F.S.A., seeking reduction in the payment

Vandervoort v. Vandervoort

277 So. 2d 43

District Court of Appeal of Florida | Filed: Apr 24, 1973 | Docket: 1730456

Cited 10 times | Published

final judgment allowing alimony to the wife (Section 61.14, F.S. 1967, F.S.A.), there is no statutory authority

Zeballos v. Zeballos

951 So. 2d 972, 2007 WL 750423

District Court of Appeal of Florida | Filed: Mar 14, 2007 | Docket: 1682578

Cited 9 times | Published

at hearing, and the factors set forth in Florida Statute 61.14, it is clear that a long-term supportive

Crupi v. Crupi

784 So. 2d 611, 2001 WL 523392

District Court of Appeal of Florida | Filed: May 18, 2001 | Docket: 437634

Cited 9 times | Published

have reduced the value of the assets. [2] Section 61.14(1)(a) provides that when the parties enter into

Pyne v. Black

650 So. 2d 1073, 1995 WL 63070

District Court of Appeal of Florida | Filed: Feb 17, 1995 | Docket: 1703079

Cited 9 times | Published

Allen, 377 So.2d 798 (Fla. 1st DCA 1979). See also § 61.14(6)(a)3. [12] See Brock v. Hudson, 494 So.2d 285

Thomas v. Thomas

589 So. 2d 944, 1991 WL 215046

District Court of Appeal of Florida | Filed: Oct 21, 1991 | Docket: 1441054

Cited 9 times | Published

some discussion of this issue is necessary. Section 61.14(1), Florida Statutes (1989), allows a party

Yohem v. Yohem

324 So. 2d 160

District Court of Appeal of Florida | Filed: Dec 19, 1975 | Docket: 1248528

Cited 9 times | Published

circumstances, to seek modification pursuant to Fla. Stat. § 61.14 (1973). Wilson v. Wilson, supra; Schwartz v. Schwartz

Gilbert v. Gilbert

312 So. 2d 511

District Court of Appeal of Florida | Filed: Apr 29, 1975 | Docket: 1411935

Cited 9 times | Published

and therefor not subject to modification under § 61.14 Fla. Stat., F.S.A., as contended for by the appellant

Sikes v. Sikes

286 So. 2d 210

District Court of Appeal of Florida | Filed: Dec 11, 1973 | Docket: 1714623

Cited 9 times | Published

jurisdiction loses its force in the face of F.S., Section 61.14, F.S.A., which provides, inter alia, that when

Spencer v. Spencer

242 So. 2d 786

District Court of Appeal of Florida | Filed: Nov 6, 1970 | Docket: 1336636

Cited 9 times | Published

cites several cases supporting the theory that Section 61.14, Florida Statutes, F.S.A. (formerly § 65.15

Stewart v. Carr

218 So. 2d 525

District Court of Appeal of Florida | Filed: Feb 7, 1969 | Docket: 1516483

Cited 9 times | Published

contemplation of the modification statute, F.S. § 61.14 F.S.A.[1]; that paragraph 11 of the petition, relating

Daniel Windsor v. Tiffany Windsor

262 So. 3d 853

District Court of Appeal of Florida | Filed: Dec 28, 2018 | Docket: 8462704

Cited 8 times | Published

prerequisite to any change in support obligations, see § 61.14, Fla. Stat.—and it also concluded that the ex-husband

Perez v. Perez

973 So. 2d 1227, 2008 WL 183314

District Court of Appeal of Florida | Filed: Jan 23, 2008 | Docket: 1292037

Cited 8 times | Published

decreasing or increasing the amount of alimony. § 61.14(1)(a), Fla. Stat. (2006). In petitioning to permanently

Alois v. Alois

937 So. 2d 171, 2006 WL 2265417

District Court of Appeal of Florida | Filed: Aug 9, 2006 | Docket: 1513099

Cited 8 times | Published

cannot afford to pay. *176 As Florida Statute section 61.14(5)(a) states: When a court of competent jurisdiction

State, Dept. of Revenue v. Sumblin

675 So. 2d 691, 1996 WL 343016

District Court of Appeal of Florida | Filed: Jun 25, 1996 | Docket: 1694643

Cited 8 times | Published

at least not when an increase is sought. See Section 61.14(7), Fla. Stat.; Matthews. Rather than simply

Zolonz v. Zolonz

659 So. 2d 451, 1995 WL 480677

District Court of Appeal of Florida | Filed: Aug 16, 1995 | Docket: 1748063

Cited 8 times | Published

notwithstanding." Holland, 602 So.2d at 654. Under section 61.14(1), Florida Statutes (1993), the court has the

Snedaker v. Snedaker

660 So. 2d 1070, 1995 WL 455451

District Court of Appeal of Florida | Filed: Aug 2, 1995 | Docket: 1755902

Cited 8 times | Published

concern involves the issue of modification. Section 61.14(1), Florida Statutes (1993), vests the circuit

Tenneboe v. Tenneboe

558 So. 2d 470, 1990 WL 26204

District Court of Appeal of Florida | Filed: Mar 14, 1990 | Docket: 1361318

Cited 8 times | Published

Bailey, 300 So.2d 294 (Fla. 4th DCA 1974). See § 61.14, Fla. Stat. (1987).

Clemson v. Clemson

546 So. 2d 75, 1989 WL 72106

District Court of Appeal of Florida | Filed: Jun 30, 1989 | Docket: 1442920

Cited 8 times | Published

attention of the court for modification of this award. § 61.14(1), Fla. Stat. (1988). Similarly, we find no abuse

Lee v. Lee

544 So. 2d 1083, 1989 WL 61528

District Court of Appeal of Florida | Filed: Jun 9, 1989 | Docket: 1301129

Cited 8 times | Published

for contempt based on arrearages in alimony. Section 61.14, Florida Statutes (1987), governs the modification

Veach v. Veach

407 So. 2d 308

District Court of Appeal of Florida | Filed: Dec 14, 1981 | Docket: 467453

Cited 8 times | Published

jurisdiction. Consequently, he argues that under Section 61.14(1) of the Florida Statutes (1979) the Court

Bailey v. Malone

389 So. 2d 348

District Court of Appeal of Florida | Filed: Oct 27, 1980 | Docket: 1281917

Cited 8 times | Published

and venue were alleged under Florida Statutes § 61.14, which provides: When the parties have entered

Bradley v. Bradley

347 So. 2d 789

District Court of Appeal of Florida | Filed: Jun 28, 1977 | Docket: 1687324

Cited 8 times | Published

alimony and/or child support awards herein under Section 61.14(1), Florida Statutes (1975), even though there

White v. White

338 So. 2d 883

District Court of Appeal of Florida | Filed: Oct 26, 1976 | Docket: 1511797

Cited 8 times | Published

was not subject to modification pursuant to Section 61.14 Florida Statutes (1975). We cannot agree. Despite

Donner v. Donner

302 So. 2d 452

District Court of Appeal of Florida | Filed: Sep 24, 1974 | Docket: 1742336

Cited 8 times | Published

Underwood, Fla. 1953, 64 So.2d 281; Fla. Stat. § 61.14, F.S.A.], the above-quoted language was intended

Maroun v. Maroun

277 So. 2d 572

District Court of Appeal of Florida | Filed: May 8, 1973 | Docket: 1730485

Cited 8 times | Published

modification of the judgment pursuant to F.S. § 61.14 F.S.A. Affirmed in part, reversed in part and remanded

Melin v. Melin

265 So. 2d 414

District Court of Appeal of Florida | Filed: Aug 8, 1972 | Docket: 1394958

Cited 8 times | Published

alimony judgments was permitted under the old law, § 61.14, Fla. Stat. 1969, F.S.A., whether the judgment

Amendments to the Florida Family Law Rules

713 So. 2d 1, 23 Fla. L. Weekly Supp. 105, 1998 Fla. LEXIS 475, 1998 WL 166533

Supreme Court of Florida | Filed: Feb 26, 1998 | Docket: 1732751

Cited 7 times | Published

order. The language apparently is derived from section 61.14(5)(a), Florida Statutes (1997), which addresses

Echols v. Elswick

638 So. 2d 581, 1994 WL 267921

District Court of Appeal of Florida | Filed: Jun 20, 1994 | Docket: 1652540

Cited 7 times | Published

that time to modify his alimony payments. See § 61.14(1), Fla. Stat. (1991). We conclude that the trial

Whight v. Whight

635 So. 2d 135, 1994 WL 122840

District Court of Appeal of Florida | Filed: Apr 13, 1994 | Docket: 1353075

Cited 7 times | Published

Stat. (Supp. 1992). A parallel provision in section 61.14(1), Florida Statutes (Supp. 1992) (enforcement

Simzer v. Simzer

514 So. 2d 372, 12 Fla. L. Weekly 2142

District Court of Appeal of Florida | Filed: Sep 4, 1987 | Docket: 1466997

Cited 7 times | Published

result in a substantial change of circumstances. § 61.14(1), Fla. Stat. (1985); Canakaris, 382 So.2d at

Essex v. Ayres

503 So. 2d 1365, 55 U.S.L.W. 2583

District Court of Appeal of Florida | Filed: Mar 17, 1987 | Docket: 1453638

Cited 7 times | Published

simply irrelevant.[2] Nothing contained in Section 61.14(1), Florida Statutes (1983), compels any contrary

Kernan v. Kernan

495 So. 2d 275, 11 Fla. L. Weekly 2098

District Court of Appeal of Florida | Filed: Oct 2, 1986 | Docket: 383069

Cited 7 times | Published

circumstances *276 and increased ability. See § 61.14, Fla. Stat. (1985). We find no error, however,

Newsome v. Newsome

456 So. 2d 520

District Court of Appeal of Florida | Filed: Sep 13, 1984 | Docket: 1447679

Cited 7 times | Published

further extension or modification pursuant to section 61.14, Florida Statutes. Wolfe v. Wolfe, 424 So.2d

Philipose v. Philipose

431 So. 2d 698

District Court of Appeal of Florida | Filed: May 20, 1983 | Docket: 456114

Cited 7 times | Published

provisions providing for modification of alimony. § 61.14, Fla. Stat. (1981). See Zimmer v. Zimmer, 328 So

Farkas v. Farkas

426 So. 2d 1213

District Court of Appeal of Florida | Filed: Feb 9, 1983 | Docket: 2510598

Cited 7 times | Published

support, either party may apply for modification. § 61.14, Fla. Stat. (1981). Thus, the crux of this appeal

Broudy v. Broudy

423 So. 2d 504

District Court of Appeal of Florida | Filed: Dec 14, 1982 | Docket: 544661

Cited 7 times | Published

of dissolution was modifiable, pursuant to Section 61.14, Florida Statutes (1973), or whether it constituted

Steffens v. Steffens

422 So. 2d 963

District Court of Appeal of Florida | Filed: Nov 10, 1982 | Docket: 1479321

Cited 7 times | Published

court does have such authority, granted by Section 61.14, Florida Statutes (1981), it is conditioned

Steffens v. Steffens

422 So. 2d 963

District Court of Appeal of Florida | Filed: Nov 10, 1982 | Docket: 1479321

Cited 7 times | Published

court does have such authority, granted by Section 61.14, Florida Statutes (1981), it is conditioned

Muss v. Muss

390 So. 2d 415

District Court of Appeal of Florida | Filed: Nov 12, 1980 | Docket: 1750280

Cited 7 times | Published

to increase her alimony payments pursuant to Section 61.14, Florida Statutes (1979). The trial court, applying

Frizzell v. Bartley

372 So. 2d 1371

Supreme Court of Florida | Filed: Jul 5, 1979 | Docket: 1695544

Cited 7 times | Published

to modify alimony and support prescribed in section 61.14, Florida Statutes (1977),[1] because it allows

Fagan v. Lewis

374 So. 2d 18

District Court of Appeal of Florida | Filed: Jul 3, 1979 | Docket: 430632

Cited 7 times | Published

subject to modification under the provisions of Section 61.14, Florida Statutes (1977). Underwood v. Underwood

McBride v. McBride

352 So. 2d 1254

District Court of Appeal of Florida | Filed: Dec 15, 1977 | Docket: 1704456

Cited 7 times | Published

Bailey, 204 So.2d 531 (Fla. 3rd DCA 1967). Section 61.14, Florida Statutes, provides that the circuit

Cohen v. Cohen

346 So. 2d 1047

District Court of Appeal of Florida | Filed: May 27, 1977 | Docket: 1411181

Cited 7 times | Published

sought only by the parties to the decree. See Section 61.14, Florida Statutes (1975). However, the state

Mintz v. Ellison

233 So. 2d 156

District Court of Appeal of Florida | Filed: Mar 10, 1970 | Docket: 1767285

Cited 7 times | Published

109 So.2d 602. Special exceptions are made by § 61.14, Fla. Stat., F.S.A. (providing for the modification

Chandler v. Chandler

226 So. 2d 697

District Court of Appeal of Florida | Filed: Sep 26, 1969 | Docket: 449593

Cited 7 times | Published

as to additional child support.[3] *699 F.S. Section 61.14, F.S.A. 1967, permits either party to petition

Jarrard v. Jarrard

157 So. 3d 332, 2015 Fla. App. LEXIS 107, 2015 WL 72356

District Court of Appeal of Florida | Filed: Jan 7, 2015 | Docket: 2621515

Cited 6 times | Published

engaged in a “supportive relationship” under section 61.14(l)(b), Florida Statutes (2005)); see also

Koski v. Koski

98 So. 3d 93, 2012 Fla. App. LEXIS 11277, 2012 WL 2813867

District Court of Appeal of Florida | Filed: Jul 11, 2012 | Docket: 60312862

Cited 6 times | Published

considered in modification proceedings under section 61.14.”). We are unable to conclude based on the hearing

King v. King

82 So. 3d 1124, 2012 Fla. App. LEXIS 3675, 2012 WL 716040

District Court of Appeal of Florida | Filed: Mar 7, 2012 | Docket: 2412861

Cited 6 times | Published

[[1]] With respect to the factors set forth in section 61.14(1)(b)(2), Florida Statutes (2008), the trial

Eisemann v. Eisemann

5 So. 3d 760, 2009 Fla. App. LEXIS 1765, 2009 WL 564237

District Court of Appeal of Florida | Filed: Mar 6, 2009 | Docket: 1664163

Cited 6 times | Published

supreme court considered the application of section 61.14(1), Florida Statutes (1985), which states that

Antepenko v. Antepenko

824 So. 2d 214, 2002 WL 1559035

District Court of Appeal of Florida | Filed: Jul 17, 2002 | Docket: 1435096

Cited 6 times | Published

focused on Mr. Antepenko's ability to pay. Under section 61.14(1), Florida Statutes (1997), if the "circumstance

Weiser v. Weiser

782 So. 2d 986, 2001 WL 387947

District Court of Appeal of Florida | Filed: Apr 18, 2001 | Docket: 456429

Cited 6 times | Published

addressed at a modification proceeding pursuant to section 61.14(1)(a), Florida Statutes (1999). Conclusion

Fendi Srl v. Condotti Shops, Inc.

754 So. 2d 755

District Court of Appeal of Florida | Filed: Mar 8, 2000 | Docket: 1523523

Cited 6 times | Published

of proper venue was determined by reviewing Section 61.14, Florida Statutes, which provides that an action

Jones v. Jones

671 So. 2d 852, 1996 WL 170192

District Court of Appeal of Florida | Filed: Apr 12, 1996 | Docket: 1248370

Cited 6 times | Published

meet his support obligations. Id. at 1278-1279; § 61.14(5), Fla. Stat. (1993). In this case, the husband

Dowie v. Dowie

668 So. 2d 290, 21 Fla. L. Weekly Fed. D 489

District Court of Appeal of Florida | Filed: Feb 20, 1996 | Docket: 1290507

Cited 6 times | Published

daughter's marriage before graduation under section 61.14(1), Florida Statutes (1993), but he failed to

Pag v. Af

602 So. 2d 1259, 17 Fla. L. Weekly Supp. 349, 1992 Fla. LEXIS 1032, 1992 WL 125120

Supreme Court of Florida | Filed: Jun 11, 1992 | Docket: 1321713

Cited 6 times | Published

of *1261 child support brought pursuant to section 61.14(1). Id. (Gunther, J., dissenting). Based upon

DHRS v. Atterberry

578 So. 2d 485, 1991 WL 61800

District Court of Appeal of Florida | Filed: Apr 25, 1991 | Docket: 441398

Cited 6 times | Published

installments become judgments by operation of law. § 61.14(5), Fla. Stat. (1989). Past due installments cannot

Williams v. Starnes

522 So. 2d 469, 1988 WL 22259

District Court of Appeal of Florida | Filed: Mar 16, 1988 | Docket: 1192403

Cited 6 times | Published

resides. We note, as we did in Marshall, that section 61.14, Florida Statutes (1987), pertaining to modification

Adams v. Adams

423 So. 2d 596

District Court of Appeal of Florida | Filed: Dec 21, 1982 | Docket: 1528758

Cited 6 times | Published

twenty-one is if he files a motion to modify under Section 61.14, Florida Statutes (1977), and is able to show

George v. George

360 So. 2d 1107

District Court of Appeal of Florida | Filed: Jun 27, 1978 | Docket: 1474834

Cited 6 times | Published

The liberal provision for modification by Section 61.14, Florida Statutes (1975), contemplates that

Siegel v. Zimmerman

319 So. 2d 187

District Court of Appeal of Florida | Filed: Sep 2, 1975 | Docket: 444331

Cited 6 times | Published

[such] orders as equity requires." See Fla. Stat. § 61.14. The greatest consideration must always be given

Cantor v. Cantor

306 So. 2d 596

District Court of Appeal of Florida | Filed: Jan 24, 1975 | Docket: 1376667

Cited 6 times | Published

Modification. With this we disagree. Florida Statutes, § 61.14, provides as follows: Modification of alimony

Cantor v. Cantor

306 So. 2d 596

District Court of Appeal of Florida | Filed: Jan 24, 1975 | Docket: 1376667

Cited 6 times | Published

Modification. With this we disagree. Florida Statutes, § 61.14, provides as follows: Modification of alimony

Blackmon v. Blackmon

307 So. 2d 887

District Court of Appeal of Florida | Filed: Dec 31, 1974 | Docket: 338512

Cited 6 times | Published

Melin v. Melin, Fla. App. 1972, 265 So.2d 414; § 61.14(1), Fla. Stat. We hold that the trial judge having

Simonet v. Simonet

279 So. 2d 35

District Court of Appeal of Florida | Filed: Jun 8, 1973 | Docket: 425442

Cited 6 times | Published

review the situation on a motion to modify under § 61.14, F.S. 1971, F.S.A. Affirmed. REED, C.J., and WALDEN

Martin v. Martin

256 So. 2d 553

District Court of Appeal of Florida | Filed: Jan 14, 1972 | Docket: 427876

Cited 6 times | Published

OWEN, Judge. Pursuant to the provision of Section 61.14, F.S. 1969, F.S.A., appellant filed in the circuit

Rogers v. Rogers

229 So. 2d 618

District Court of Appeal of Florida | Filed: Dec 19, 1969 | Docket: 430113

Cited 6 times | Published

language of our modification statute itself, F.S. § 61.14 F.S.A. (formerly § 65.15 F.S.), which reads inter

Thompson v. Thompson

223 So. 2d 95

District Court of Appeal of Florida | Filed: May 23, 1969 | Docket: 522331

Cited 6 times | Published

of divorce in accordance with the provisions of § 61.14, F.S.A. The original decree of divorce herein provided

ROBERT W. BAUCHMAN v. BERTA BAUCHMAN

253 So. 3d 1143

District Court of Appeal of Florida | Filed: Aug 15, 2018 | Docket: 7664426

Cited 5 times | Published

due regard to the changed circumstances . . . .” § 61.14(1)(a), Fla. Stat. (2017). However, the appellate

ROBERT W. BAUCHMAN v. BERTA BAUCHMAN

253 So. 3d 1143

District Court of Appeal of Florida | Filed: Aug 15, 2018 | Docket: 7664426

Cited 5 times | Published

due regard to the changed circumstances . . . .” § 61.14(1)(a), Fla. Stat. (2017). However, the appellate

Ivanovich v. Valladarez

190 So. 3d 1144, 2016 Fla. App. LEXIS 6689, 2016 WL 2247951

District Court of Appeal of Florida | Filed: May 4, 2016 | Docket: 3060710

Cited 5 times | Published

filed five months later); see also § 61.14(1), Fla. Stat. (2009 & 2010) (providing that upon

Fort v. Fort

951 So. 2d 1020, 2007 WL 879012

District Court of Appeal of Florida | Filed: Mar 26, 2007 | Docket: 1280312

Cited 5 times | Published

unless there is a reservation of jurisdiction. § 61.14, Fla. Stat. (2005); Encarnacion v. Encarnacion

Amend. to Rules of App. Proc., Civ. Proc.

887 So. 2d 1090, 2004 WL 2201732

Supreme Court of Florida | Filed: Sep 30, 2004 | Docket: 1515169

Cited 5 times | Published

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Kuttas v. Ritter

879 So. 2d 3, 2004 WL 912663

District Court of Appeal of Florida | Filed: Apr 30, 2004 | Docket: 379424

Cited 5 times | Published

the filing of the petition for modification. Section 61.14(1)(a) states that "the court may modify an order

Knight v. Knight

702 So. 2d 242, 1997 WL 715590

District Court of Appeal of Florida | Filed: Nov 19, 1997 | Docket: 460230

Cited 5 times | Published

was not based upon such agreement. Relying on section 61.14(7), Florida Statutes, which was added in 1993

Calicchio v. Calicchio

693 So. 2d 1124, 1997 WL 269176

District Court of Appeal of Florida | Filed: May 21, 1997 | Docket: 2561765

Cited 5 times | Published

to state reasons for granting the motion. See § 61.14(5)(a), Fla. Stat. (1995). The order states, "Respondent

Matthews v. Matthews

677 So. 2d 323, 1996 WL 191046

District Court of Appeal of Florida | Filed: Apr 23, 1996 | Docket: 1690135

Cited 5 times | Published

Guadine, 474 So.2d 1245 (Fla. 4th DCA 1985); § 61.14(1), Fla. Stat. (Supp.1994). Even when a court of

Kranz v. Kranz

661 So. 2d 876, 1995 WL 581377

District Court of Appeal of Florida | Filed: Oct 5, 1995 | Docket: 532317

Cited 5 times | Published

further consistent proceedings. NOTES [1] Section 61.14(6)(a)(1), Florida Statutes (1993), provides

Castillo v. Castillo

626 So. 2d 1035, 1993 WL 460650

District Court of Appeal of Florida | Filed: Nov 9, 1993 | Docket: 1684996

Cited 5 times | Published

when, and if, the husband's income increases. See § 61.14(1), Fla. Stat. (1991); Poe v. Poe, 263 So.2d 644

DEPT. OF H & R SERV. v. Beckwith

624 So. 2d 395

District Court of Appeal of Florida | Filed: Sep 24, 1993 | Docket: 475732

Cited 5 times | Published

dismissed, 478 So.2d 53 (Fla. 1985). See also § 61.14(5), Fla. Stat. (1991). Accordingly, we hold that

Bedell v. Bedell

561 So. 2d 1179, 1989 WL 133261

District Court of Appeal of Florida | Filed: Nov 7, 1989 | Docket: 1740254

Cited 5 times | Published

to such an increase as a matter of law under Section 61.14(1), Florida Statutes (1985), based solely on

Fayson v. Fayson

482 So. 2d 523, 11 Fla. L. Weekly 298

District Court of Appeal of Florida | Filed: Jan 30, 1986 | Docket: 159043

Cited 5 times | Published

jurisdiction to modify child support obligations. § 61.14, Fla. Stat. (1983). Here, the husband was ordered

Urbanek v. Urbanek

484 So. 2d 597, 11 Fla. L. Weekly 251

District Court of Appeal of Florida | Filed: Jan 22, 1986 | Docket: 1343811

Cited 5 times | Published

its incorporation into the final judgment. Section 61.14(1), Florida Statutes, provides: Modification

White v. Bacardi

446 So. 2d 150

District Court of Appeal of Florida | Filed: Jan 24, 1984 | Docket: 1780269

Cited 5 times | Published

modification in light of changed circumstances. § 61.14(1), Fla. Stat. (1981). When the alimony award is

Cotton v. Cotton

439 So. 2d 309

District Court of Appeal of Florida | Filed: Oct 7, 1983 | Docket: 1265747

Cited 5 times | Published

Sapp v. Sapp, 275 So.2d 43 (Fla. 2d DCA 1973); § 61.14, Fla. Stat. (1981). The other arguments advanced

Marshall v. Marshall

404 So. 2d 1182

District Court of Appeal of Florida | Filed: Oct 23, 1981 | Docket: 2084570

Cited 5 times | Published

Poliak, 235 So.2d 512 (Fla. 2d DCA 1970). Section 61.14, Florida Statutes (1979), which permits the

Burgdorf v. Burgdorf

372 So. 2d 988

District Court of Appeal of Florida | Filed: Jul 6, 1979 | Docket: 1325588

Cited 5 times | Published

twenty-one is if he files a motion to modify under Section 61.14, Florida Statutes (1977), and is able to prove

Coffin v. Coffin

368 So. 2d 105

District Court of Appeal of Florida | Filed: Mar 7, 1979 | Docket: 1723299

Cited 5 times | Published

minor children of the parties. Pursuant to Section 61.14, Florida Statutes (1975), the circuit court

Stickney v. Stickney

377 So. 2d 187

District Court of Appeal of Florida | Filed: Jan 31, 1979 | Docket: 423300

Cited 5 times | Published

thereof." (emphasis theirs) Under Florida Statute § 61.14 the trial court has jurisdiction as a matter of

Friedman v. Friedman

366 So. 2d 820

District Court of Appeal of Florida | Filed: Jan 16, 1979 | Docket: 250925

Cited 5 times | Published

court, speaking through Judge Hubbart, said: "Section 61.14(1) Florida Statutes (1975), gives a trial court

Hosford v. Hosford

362 So. 2d 973

District Court of Appeal of Florida | Filed: Sep 12, 1978 | Docket: 22898

Cited 5 times | Published

occurring since the prior award. Florida Statute § 61.14. Once the court has found sufficient change in

Manganiello v. Manganiello

359 So. 2d 26

District Court of Appeal of Florida | Filed: May 30, 1978 | Docket: 1417843

Cited 5 times | Published

is able to show on a motion to modify under Section 61.14, Florida Statutes (1977), that the child has

Gratton v. Gratton

358 So. 2d 262

District Court of Appeal of Florida | Filed: May 9, 1978 | Docket: 1311310

Cited 5 times | Published

of the parties the husband could apply under Section 61.14, Florida Statutes (1977) for modification of

Hyotlaine v. Hyotlaine

356 So. 2d 1319

District Court of Appeal of Florida | Filed: Apr 4, 1978 | Docket: 1478595

Cited 5 times | Published

increasing the amount provided for in the agreement. Section 61.14, Florida Statutes (1975). On the other hand

Freeland v. Purcifull

347 So. 2d 726

District Court of Appeal of Florida | Filed: Jun 15, 1977 | Docket: 1291097

Cited 5 times | Published

Chastain v. Chastain, 73 So.2d 66 (Fla. 1954); See Section 61.14(1), Florida Statutes (1975); Quinn v. Quinn

Elliott v. Weyman

337 So. 2d 832

District Court of Appeal of Florida | Filed: Sep 28, 1976 | Docket: 1414309

Cited 5 times | Published

County, the circuit court of that county under § 61.14, Fla. Stat. (1975), "has jurisdiction to make orders

Wilisch v. Wilisch

335 So. 2d 861

District Court of Appeal of Florida | Filed: Aug 3, 1976 | Docket: 1306235

Cited 5 times | Published

modification was properly made pursuant to Fla. Stat. § 61.14.[2] This statute does not authorize a trial judge

Zimmer v. Zimmer

328 So. 2d 525

District Court of Appeal of Florida | Filed: Mar 19, 1976 | Docket: 2541917

Cited 5 times | Published

alimony is not subject to modification pursuant to § 61.14 F.S. 1973. Gordon v. Gordon, Fla.App.3d, 1967,

Newton v. Newton

245 So. 2d 45

Supreme Court of Florida | Filed: Feb 17, 1971 | Docket: 1356439

Cited 5 times | Published

Florida pursuant to the provisions of F.S. Section 61.14, F.S.A. Inasmuch as Respondent amended her complaint

Regan v. Regan

217 So. 3d 91, 2017 WL 1363973, 2017 Fla. App. LEXIS 5058

District Court of Appeal of Florida | Filed: Apr 12, 2017 | Docket: 60266097

Cited 4 times | Published

obligation. Both parties appeal this final judgment. Section 61.14, Florida Statutes (2015), provides for the ability

Hahamovitch v. Hahamovitch

133 So. 3d 1008, 2014 WL 52717, 2014 Fla. App. LEXIS 135

District Court of Appeal of Florida | Filed: Jan 8, 2014 | Docket: 60238643

Cited 4 times | Published

decrease under changed conditions as provided in section 61.14, Florida Statutes, as the parties are assumed

Mann v. Yeatts

111 So. 3d 934, 2013 Fla. App. LEXIS 5597, 2013 WL 1348611

District Court of Appeal of Florida | Filed: Apr 5, 2013 | Docket: 60230917

Cited 4 times | Published

modification of a paternity support order, pursuant to section 61.14, Florida Statutes, in his home county of Putnam

Nabinger v. Nabinger

82 So. 3d 1075, 2011 Fla. App. LEXIS 20898, 2011 WL 6851182

District Court of Appeal of Florida | Filed: Dec 30, 2011 | Docket: 1935623

Cited 4 times | Published

result. § 61.30(11)(a), Fla. Stat.; see also, § 61.14, Fla. Stat. (equitable result desired in modification

Elliott v. Bradshaw

59 So. 3d 1182, 2011 Fla. App. LEXIS 5114, 2011 WL 1346902

District Court of Appeal of Florida | Filed: Apr 11, 2011 | Docket: 60299578

Cited 4 times | Published

factual basis for that finding”). Pursuant to section 61.14(5)(a), Florida Statutes (2010), husband is presumed

Elliott v. Bradshaw

59 So. 3d 1182, 2011 Fla. App. LEXIS 5114, 2011 WL 1346902

District Court of Appeal of Florida | Filed: Apr 11, 2011 | Docket: 60299578

Cited 4 times | Published

factual basis for that finding”). Pursuant to section 61.14(5)(a), Florida Statutes (2010), husband is presumed

Bieda v. Bieda

42 So. 3d 859, 2010 Fla. App. LEXIS 11724, 2010 WL 3154834

District Court of Appeal of Florida | Filed: Aug 11, 2010 | Docket: 1148767

Cited 4 times | Published

him notice and a time for response. Although section 61.14(6)(a)(1), Florida Statutes (2009), provides

Wilson v. Wilson

37 So. 3d 877, 2010 Fla. App. LEXIS 5248, 2010 WL 1563663

District Court of Appeal of Florida | Filed: Apr 21, 2010 | Docket: 1668730

Cited 4 times | Published

per month previously established. Analysis Section 61.14, Florida Statutes (2007), provides in relevant

French v. French

4 So. 3d 5, 2009 Fla. App. LEXIS 337, 2009 WL 129587

District Court of Appeal of Florida | Filed: Jan 21, 2009 | Docket: 1666548

Cited 4 times | Published

terminate alimony payments. We agree and reverse. Section 61.14(1)(b)1., Florida Statutes (2006) provides for

Linstroth v. Dorgan

2 So. 3d 305, 2008 Fla. App. LEXIS 8434, 2008 WL 2356760

District Court of Appeal of Florida | Filed: Jun 11, 2008 | Docket: 1137996

Cited 4 times | Published

obligation, citing the recent enactment of section 61.14(1)(b), Florida Statutes (2005). The former wife

Murphy v. Murphy

948 So. 2d 864, 2007 WL 283036

District Court of Appeal of Florida | Filed: Feb 2, 2007 | Docket: 1769923

Cited 4 times | Published

decisions were rendered prior to the enactment of section 61.14(11), Florida Statutes. This statute became effective

Esteva v. Rodriguez

913 So. 2d 684, 2005 WL 2373426

District Court of Appeal of Florida | Filed: Sep 28, 2005 | Docket: 1331451

Cited 4 times | Published

modifications), they do not mandate such an award. See § 61.14, Fla. Stat. (2004) (authorizing modification of

Koll v. Koll

812 So. 2d 529, 2002 WL 460385

District Court of Appeal of Florida | Filed: Mar 27, 2002 | Docket: 1364004

Cited 4 times | Published

Jenne, 721 So.2d 380, 383 (Fla. 4th DCA 1998); § 61.14, Fla. Stat. (2000). Here, the court did not consider

Amendments to the Florida Family Law Rules of Procedure & Family Law Forms

810 So. 2d 1, 26 Fla. L. Weekly Supp. 13, 2000 Fla. LEXIS 2272, 2000 WL 1352932

Supreme Court of Florida | Filed: Sep 21, 2000 | Docket: 64813197

Cited 4 times | Published

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Cole v. Cole

723 So. 2d 925, 1999 WL 9791

District Court of Appeal of Florida | Filed: Jan 13, 1999 | Docket: 1319781

Cited 4 times | Published

precarious immigration status in this country. See § 61.14(1)(c), Fla. Stat. (1995); Held, 617 So.2d at 360;

Mallardi v. Jenne

721 So. 2d 380, 1998 WL 821758

District Court of Appeal of Florida | Filed: Nov 6, 1998 | Docket: 1694556

Cited 4 times | Published

out of jail. In 1992 the legislature amended section 61.14 to provide the following: "When a court of competent

Spano v. Spano

698 So. 2d 324, 1997 WL 442355

District Court of Appeal of Florida | Filed: Aug 6, 1997 | Docket: 434568

Cited 4 times | Published

as regards the ability to modify a judgment. Section 61.14(1) provides: "When the parties enter into an

Washington v. Washington

613 So. 2d 594, 1993 WL 32452

District Court of Appeal of Florida | Filed: Feb 12, 1993 | Docket: 454187

Cited 4 times | Published

venue is proper in Seminole County, pursuant to section 61.14(1), Florida Statutes. We agree and reverse.

Washington v. Washington

613 So. 2d 594, 1993 WL 32452

District Court of Appeal of Florida | Filed: Feb 12, 1993 | Docket: 454187

Cited 4 times | Published

venue is proper in Seminole County, pursuant to section 61.14(1), Florida Statutes. We agree and reverse.

Lewis v. Lewis

569 So. 2d 1342, 1990 WL 175080

District Court of Appeal of Florida | Filed: Nov 9, 1990 | Docket: 1660593

Cited 4 times | Published

AFDC payments. According to both Bailey and section 61.14, F.S., then, the petition could have been properly

Kuhnke v. Kuhnke

556 So. 2d 1121, 1989 WL 110946

District Court of Appeal of Florida | Filed: Sep 26, 1989 | Docket: 542966

Cited 4 times | Published

Coffin, 368 So.2d 105 (Fla. 4th DCA 1979); see also § 61.14, Fla. Stat. (1975), they do not justify modification

Fritz v. Fritz

485 So. 2d 488, 11 Fla. L. Weekly 727

District Court of Appeal of Florida | Filed: Mar 25, 1986 | Docket: 1680762

Cited 4 times | Published

financial responsibility for raising the children. See § 61.14, Fla. Stat. (1983) (gives court authority to modify

Brown v. Brown

472 So. 2d 873, 10 Fla. L. Weekly 1765

District Court of Appeal of Florida | Filed: Jul 17, 1985 | Docket: 1793755

Cited 4 times | Published

of proof than otherwise would be required. See § 61.14, Fla. Stat.(1983); Webber v. Webber, 156 Fla. 396

Morin v. Morin

466 So. 2d 1255, 10 Fla. L. Weekly 961

District Court of Appeal of Florida | Filed: Apr 12, 1985 | Docket: 1524952

Cited 4 times | Published

Sackler v. Sackler, 47 So.2d 292 (Fla. 1950); § 61.14, Fla. Stat. (1981). Second, Mrs. Morin argues that

Bassett v. Bassett

464 So. 2d 1203

District Court of Appeal of Florida | Filed: Feb 12, 1985 | Docket: 1661252

Cited 4 times | Published

in the broadest and most compelling terms. Section 61.14, Florida Statutes (1981), which has been in

Shaw v. Shaw

448 So. 2d 631

District Court of Appeal of Florida | Filed: Apr 25, 1984 | Docket: 1523004

Cited 4 times | Published

husband was not entitled to modification under section 61.14(1), Florida Statutes (1983), because he failed

Witter v. Witter

443 So. 2d 417

District Court of Appeal of Florida | Filed: Jan 4, 1984 | Docket: 1459065

Cited 4 times | Published

proceedings *419 consistent with the dictates of section 61.14, Florida Statutes (1981).[2] REVERSED and REMANDED

Walton v. Walton

354 So. 2d 464

District Court of Appeal of Florida | Filed: Jan 31, 1978 | Docket: 1279230

Cited 4 times | Published

case, modification of alimony judgments (Florida Statute 61.14)." The judgment of the trial court granting

Walton v. Walton

354 So. 2d 464

District Court of Appeal of Florida | Filed: Jan 31, 1978 | Docket: 1279230

Cited 4 times | Published

case, modification of alimony judgments (Florida Statute 61.14)." The judgment of the trial court granting

Mumm v. Mumm

353 So. 2d 134

District Court of Appeal of Florida | Filed: Nov 22, 1977 | Docket: 424275

Cited 4 times | Published

pay the arrearage and petitioned, pursuant to Section 61.14, Florida Statutes (1975), for modification seeking

Goldin v. Goldin

346 So. 2d 107

District Court of Appeal of Florida | Filed: May 24, 1977 | Docket: 1410159

Cited 4 times | Published

the aforesaid alimony provisions and reverse. Section 61.14(1) Florida Statutes (1975), gives a trial court

Buckley v. Buckley

343 So. 2d 890

District Court of Appeal of Florida | Filed: Feb 18, 1977 | Docket: 1710558

Cited 4 times | Published

"Respondent's Supplemental Complaint For Judgment Under F.S. 61.14" in the trial court. The relief sought in the

Ciociola v. Ciociola

302 So. 2d 462

District Court of Appeal of Florida | Filed: Oct 8, 1974 | Docket: 1742886

Cited 4 times | Published

determine whether this is an action pursuant to § 61.14, Fla. Stat., or an action to enforce the common

DeFrancisco v. DeFrancisco

273 So. 2d 780

District Court of Appeal of Florida | Filed: Mar 2, 1973 | Docket: 1512838

Cited 4 times | Published

alimony during the minority of the child. Under F.S. § 61.14 F.S.A., relating to modification of alimony judgments

Fort v. Hood's Dairy, Inc.

143 So. 2d 13

Supreme Court of Florida | Filed: Jun 27, 1962 | Docket: 1319283

Cited 4 times | Published

Vol. 2, Larson, Workmen's Compensation Law, Section 61.14. Contrary to the position taken by the employee

Faulk v. State, Department of Revenue

157 So. 3d 534, 2015 Fla. App. LEXIS 2187, 2015 WL 675083

District Court of Appeal of Florida | Filed: Feb 18, 2015 | Docket: 60246094

Cited 3 times | Published

The first paragraph of the pleading cites section 61.14(1), Florida Statutes, which discusses modification

Elbaum v. Elbaum

141 So. 3d 658, 2014 WL 2741317, 2014 Fla. App. LEXIS 9201

District Court of Appeal of Florida | Filed: Jun 18, 2014 | Docket: 60242003

Cited 3 times | Published

So.2d 350, 353 (Fla. 1st DCA 2002)). Under section 61.14(l)(b)l., Florida Statutes (2012), a court may

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

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Amendments to Approved Family Law Forms

20 So. 3d 173

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

Cited 3 times | Published

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Helling v. Bartok

987 So. 2d 713, 2008 WL 2485606

District Court of Appeal of Florida | Filed: Jun 18, 2008 | Docket: 1724063

Cited 3 times | Published

Fenner, 599 So.2d 1343, 1345 (Fla. 4th DCA 1992); § 61.14(1)(a), Fla. Stat. (2007) (providing that a "court

Vitt v. Rodriguez

960 So. 2d 47, 2007 WL 1709535

District Court of Appeal of Florida | Filed: Jun 15, 2007 | Docket: 1406191

Cited 3 times | Published

arrearages are to be applied. We note that section 61.14(6), Florida Statutes (2006), relates that unpaid

Wolfe v. Wolfe

953 So. 2d 632, 2007 WL 911830

District Court of Appeal of Florida | Filed: Mar 28, 2007 | Docket: 1338397

Cited 3 times | Published

or the decreased needs of the other party. See § 61.14(1), Fla. Stat.; Antepenko v. Antepenko, 824 So

Lámar v. Lámar

889 So. 2d 983, 2004 WL 2952755

District Court of Appeal of Florida | Filed: Dec 22, 2004 | Docket: 1488190

Cited 3 times | Published

support and to purge himself of the contempt. See § 61.14(5)(a), Fla. Stat. (2003); Bowen v. Bowen, 471 So

Miles v. Champlin

805 So. 2d 1085, 2002 WL 126186

District Court of Appeal of Florida | Filed: Feb 1, 2002 | Docket: 1669536

Cited 3 times | Published

supplemental action for modification as equity requires." § 61.14(1)(a), Fla. Stat. (2001). Any other rule might

Lottinger-Serraes v. Serraes

774 So. 2d 959, 2001 WL 50495

District Court of Appeal of Florida | Filed: Jan 17, 2001 | Docket: 1330894

Cited 3 times | Published

sought modification of a support order, see section 61.14(1)(a), Florida Statutes (1999) (authorizing

Burkhart v. Burkhart

731 So. 2d 733, 1999 WL 168548

District Court of Appeal of Florida | Filed: Mar 30, 1999 | Docket: 1733730

Cited 3 times | Published

the payment of permanent alimony. Although section 61.14, Florida Statutes, gives circuit judges authority

Skinner v. Skinner

678 So. 2d 512, 1996 WL 486177

District Court of Appeal of Florida | Filed: Aug 28, 1996 | Docket: 1737053

Cited 3 times | Published

improper venue. Appellee contends that under section 61.14(1), Florida Statutes (1995), venue is proper

Kelsey v. Kelsey

636 So. 2d 77, 1994 WL 90364

District Court of Appeal of Florida | Filed: Mar 23, 1994 | Docket: 1715359

Cited 3 times | Published

for modification. In Mouton the court stated: Section 61.14, Florida Statutes (1989), extends jurisdiction

Wiedman v. Wiedman

610 So. 2d 681, 1992 WL 371557

District Court of Appeal of Florida | Filed: Dec 18, 1992 | Docket: 1413429

Cited 3 times | Published

Chastain v. Chastain, 73 So.2d 66, 68 (Fla. 1954); § 61.14(1), Fla. Stat. (1991). Appellant had initially

Cibula v. Cibula

578 So. 2d 519, 1991 WL 65939

District Court of Appeal of Florida | Filed: May 1, 1991 | Docket: 440634

Cited 3 times | Published

modification proceedings finds its source in section 61.14 and section 61.16 of the Florida Statutes. When

Wilkinson v. Coggin

552 So. 2d 348, 1989 WL 139522

District Court of Appeal of Florida | Filed: Nov 22, 1989 | Docket: 1663752

Cited 3 times | Published

showing of change in need and ability to pay. § 61.14, Fla. Stat. (1987). This broader interpretation

Brighton v. Brighton

517 So. 2d 53, 1987 WL 2271

District Court of Appeal of Florida | Filed: Dec 9, 1987 | Docket: 1528046

Cited 3 times | Published

in circumstances of either party pursuant to section 61.14, Florida Statutes (1985), we hold that such

Florida Structures, Inc. v. Morton

443 So. 2d 444

District Court of Appeal of Florida | Filed: Jan 10, 1984 | Docket: 1746648

Cited 3 times | Published

See 2 Larson, The Law of Workmen's Compensation, § 61.14 (1982); DiGiorgio Fruit Corporation v. Pittman

Maas v. Maas

438 So. 2d 1068

District Court of Appeal of Florida | Filed: Oct 19, 1983 | Docket: 1445416

Cited 3 times | Published

as a petition to modify alimony pursuant to section 61.14, Florida Statutes (1981). This is because the

Stebbins v. Stebbins

435 So. 2d 383

District Court of Appeal of Florida | Filed: Jul 28, 1983 | Docket: 1328313

Cited 3 times | Published

an increase in the income of either part." Section 61.14, Florida Statutes (1981) gives the Court the

Vanden Bosch v. Elkins

419 So. 2d 1127

District Court of Appeal of Florida | Filed: Sep 7, 1982 | Docket: 1586162

Cited 3 times | Published

incorporates a property settlement agreement. See § 61.14, Fla. Stat. (1981); also compare Lacy v. Lacy,

Mullins v. Mullins

409 So. 2d 143

District Court of Appeal of Florida | Filed: Jan 27, 1982 | Docket: 1525414

Cited 3 times | Published

in which to file such a motion pursuant to Section 61.14, Florida Statutes (1981). *144 The trial court

Brown v. Brown

399 So. 2d 1083

District Court of Appeal of Florida | Filed: Jun 22, 1981 | Docket: 1652418

Cited 3 times | Published

need and appellee's increased ability to pay. Section 61.14(1), Florida Statutes (1979). The trial court

Gilman v. Dozier

388 So. 2d 294

District Court of Appeal of Florida | Filed: Sep 15, 1980 | Docket: 1520785

Cited 3 times | Published

twenty-one is if he files a motion to modify under Section 61.14, Florida Statutes (1977), and is able to prove

Brown v. Brown

338 So. 2d 916

District Court of Appeal of Florida | Filed: Nov 3, 1976 | Docket: 455223

Cited 3 times | Published

to obtaining additional alimony pursuant to Section 61.14, Florida Statutes (1975). A spouse who is behind

Byrd v. Byrd

324 So. 2d 659

District Court of Appeal of Florida | Filed: Dec 31, 1975 | Docket: 1672281

Cited 3 times | Published

trial court only upon a showing under Fla. Stat. § 61.14 of a change of circumstances subsequent to the

Nichols v. Nichols

304 So. 2d 497

District Court of Appeal of Florida | Filed: Dec 12, 1974 | Docket: 277016

Cited 3 times | Published

later applied for and properly allowable under § 61.14, Florida Statutes. From the record it appears that

Goldblatt v. Goldblatt

277 So. 2d 34

District Court of Appeal of Florida | Filed: May 1, 1973 | Docket: 1439482

Cited 3 times | Published

would modify the foreign judgment pursuant to F.S. § 61.14 F.S.A. The record clearly reflects that the defendant

Hurst v. Hampton

274 So. 2d 891

District Court of Appeal of Florida | Filed: Mar 16, 1973 | Docket: 1676517

Cited 3 times | Published

and appropriate modification of the judgment. Section 61.14, F.S. 1971, F.S.A. We merely say that the adjudication

Stamm v. Stamm

266 So. 2d 413

District Court of Appeal of Florida | Filed: Sep 12, 1972 | Docket: 1298800

Cited 3 times | Published

parties and subject matter, particularly in light of § 61.14, Fla. Stat., F.S.A., then he may exercise his discretion

Fishman v. Fishman

245 So. 2d 258

District Court of Appeal of Florida | Filed: Feb 2, 1971 | Docket: 1356353

Cited 3 times | Published

Frischkorn, Fla.App. 1969, 223 So.2d 380. See generally § 61.14, Fla. Stat., F.S.A. *259 Accordingly, the portion

Loftis v. Loftis

208 So. 3d 824, 2017 Fla. App. LEXIS 289

District Court of Appeal of Florida | Filed: Jan 13, 2017 | Docket: 4571009

Cited 2 times | Published

filing a petition for modification pursuant • to section 61.14(l)(a), Florida Statutes (2015). The trial

Tarkow v. Tarkow

128 So. 3d 82, 2013 WL 4525302, 2013 Fla. App. LEXIS 13640

District Court of Appeal of Florida | Filed: Aug 28, 2013 | Docket: 60237165

Cited 2 times | Published

“supportive relationship” within the meaning of section 61.14(l)(b), Florida Statutes (2009). The Former Wife

Walker v. Walker

80 So. 3d 1128, 2012 Fla. App. LEXIS 3256, 2012 WL 632590

District Court of Appeal of Florida | Filed: Feb 29, 2012 | Docket: 60305644

Cited 2 times | Published

jurisdiction to enforce and modify an alimony award. See § 61.14(l)(a), Fla. Stat. (2010); see also Wiele v. Kadzis

Warfel v. Universal Insurance Co. of North America

36 So. 3d 136, 2010 Fla. App. LEXIS 6572, 2010 WL 1874367

District Court of Appeal of Florida | Filed: May 12, 2010 | Docket: 1639037

Cited 2 times | Published

(Fla. 4th DCA 1998) (discussing amendment to section 61.14, Florida Statutes (1992), which adopted a presumption

White v. White

3 So. 3d 400, 2009 Fla. App. LEXIS 791, 2009 WL 277055

District Court of Appeal of Florida | Filed: Feb 6, 2009 | Docket: 1653166

Cited 2 times | Published

has a "supportive relationship" as envisioned by § 61.14, Florida Statutes. The supportive relationship

Bagley v. Bagley

948 So. 2d 841, 2007 WL 173918

District Court of Appeal of Florida | Filed: Jan 25, 2007 | Docket: 1082283

Cited 2 times | Published

The appellant sought modification pursuant to section 61.14(1)(b), Florida Statutes, and he contends that

Ferguson v. Ferguson

921 So. 2d 796, 2006 WL 435719

District Court of Appeal of Florida | Filed: Feb 24, 2006 | Docket: 1658373

Cited 2 times | Published

v. Hosford, 362 So.2d 973 (Fla. 1st DCA 1978); § 61.14, Fla. Stat. (2004). Where the alimony is set by

Amir v. Gannon

896 So. 2d 793, 2005 WL 176623

District Court of Appeal of Florida | Filed: Jan 28, 2005 | Docket: 1282990

Cited 2 times | Published

Hernando County. We agree and reverse. *794 Section 61.14(1), Florida Statutes, provides that a person

Garone v. Goller

878 So. 2d 430, 2004 WL 1506152

District Court of Appeal of Florida | Filed: Jul 7, 2004 | Docket: 1353508

Cited 2 times | Published

considering the support guidelines as required by section 61.14, Florida Statutes. Accordingly, the Order on

Llopis v. Llopis

731 So. 2d 719, 1999 WL 123133

District Court of Appeal of Florida | Filed: Mar 10, 1999 | Docket: 1733832

Cited 2 times | Published

necessitating the increase in payments. See Fla. Stat. § 61.14 (1995). In addition, we are somewhat baffled in

Abdella v. Abdella

693 So. 2d 637, 1997 WL 193949

District Court of Appeal of Florida | Filed: Apr 23, 1997 | Docket: 1524357

Cited 2 times | Published

Abdella appeals the order denying modification. Section 61.14 Florida Statutes (1995)provides in part: Enforcement

Finley v. Scott

687 So. 2d 338, 1997 WL 63671

District Court of Appeal of Florida | Filed: Feb 7, 1997 | Docket: 1718422

Cited 2 times | Published

"modification" and the procedure is set out in section 61.14, Florida Statutes. As a matter of fact, the

Huffman v. Huffman

596 So. 2d 718, 1992 WL 51239

District Court of Appeal of Florida | Filed: Mar 18, 1992 | Docket: 1707340

Cited 2 times | Published

to Florida Rule of Civil Procedure 1.540 and section 61.14, Florida Statutes (1989). The husband based

State Ex Rel. Pittman v. Stanjeski

541 So. 2d 1214, 1989 WL 1345

District Court of Appeal of Florida | Filed: Jan 13, 1989 | Docket: 50208

Cited 2 times | Published

constitutionality of the 1987 amendment to section 61.14, Florida Statutes (Supp. 1986). Ch. 87-95, §

Laurenzo v. Laurenzo

522 So. 2d 1065, 1988 WL 31684

District Court of Appeal of Florida | Filed: Apr 12, 1988 | Docket: 1660891

Cited 2 times | Published

Chord v. Chord, 209 So.2d 281 (Fla. 3d DCA 1968); § 61.14 Fla. Stat. (1987). Mrs. Laurenzo has demonstrated

Kirchen v. Kirchen

484 So. 2d 1308, 11 Fla. L. Weekly 586

District Court of Appeal of Florida | Filed: Mar 5, 1986 | Docket: 1344320

Cited 2 times | Published

court to conduct further proceedings under section 61.14, Florida Statutes (1983), consistent with this

Gilbert v. Gilbert

472 So. 2d 1317, 10 Fla. L. Weekly 1769

District Court of Appeal of Florida | Filed: Jul 17, 1985 | Docket: 1793990

Cited 2 times | Published

286 So.2d 210, 212 (Fla. 1st DCA 1973). See also § 61.14(1), Fla. Stat. (1983) (court has jurisdiction to

Lewis v. Lewis

450 So. 2d 1123

District Court of Appeal of Florida | Filed: Jan 25, 1984 | Docket: 1433529

Cited 2 times | Published

circumstances had occurred and, pursuant to section 61.14, Florida Statutes (1981), modified the husband's

Aoun v. Aoun

428 So. 2d 707

District Court of Appeal of Florida | Filed: Mar 1, 1983 | Docket: 1375569

Cited 2 times | Published

petition to modify the final judgment pursuant to Section 61.14, Florida Statutes (1981) was granted, effective

Dept. of Health & Rehab. Services v. Walker

411 So. 2d 347

District Court of Appeal of Florida | Filed: Mar 24, 1982 | Docket: 1696961

Cited 2 times | Published

modification upon a showing of changed circumstances. § 61.14, Fla. Stat. (1981). Presumably, the provision which

Hoffman v. Hoffman

371 So. 2d 1061

District Court of Appeal of Florida | Filed: May 29, 1979 | Docket: 1786251

Cited 2 times | Published

twenty-one is if he files a motion to modify under Section 61.14, Florida Statutes (1977), and is able to show

Hoffman v. Hoffman

371 So. 2d 1061

District Court of Appeal of Florida | Filed: May 29, 1979 | Docket: 1786251

Cited 2 times | Published

twenty-one is if he files a motion to modify under Section 61.14, Florida Statutes (1977), and is able to show

Maloy v. Maloy

362 So. 2d 484

District Court of Appeal of Florida | Filed: Sep 20, 1978 | Docket: 1715706

Cited 2 times | Published

the agreement itself. While it is true that Section 61.14, Florida Statutes (1975) permits judicial modification

Douglas v. Douglas

361 So. 2d 212

District Court of Appeal of Florida | Filed: Aug 2, 1978 | Docket: 1288138

Cited 2 times | Published

petition the trial court for modification. Section 61.14, Florida Statutes (1975); Wilson v. Wilson,

Hall v. AIR FORCE FINANCE CTR., ETC.

344 So. 2d 1340

District Court of Appeal of Florida | Filed: May 2, 1977 | Docket: 1517743

Cited 2 times | Published

to § 61.08; § 65.11 with § 61.11; § 65.15 with § 61.14 and § 65.20 with § 61.19.

Singer v. Singer

318 So. 2d 438

District Court of Appeal of Florida | Filed: Jul 18, 1975 | Docket: 1739212

Cited 2 times | Published

circumstances and conditions as provided in Fla. Stat. § 61.14. Subsequently, the Posner case was again before

In Re Estate of Humphreys

299 So. 2d 595

Supreme Court of Florida | Filed: Jun 26, 1974 | Docket: 1499388

Cited 2 times | Published

of persons who have claims upon the estate. Section 61.14, F.S. 1969, F.S.A., which was in effect at the

Zilbert v. Zilbert

287 So. 2d 100

District Court of Appeal of Florida | Filed: Dec 21, 1973 | Docket: 1170496

Cited 2 times | Published

subject to review under Fla. Stat. § 61.13 and § 61.14, F.S.A. We have examined the other points raised

Putnam v. Putnam

226 So. 2d 30

District Court of Appeal of Florida | Filed: Jun 25, 1969 | Docket: 449644

Cited 2 times | Published

not subject to modification under F.S. 1967, Section 61.14, F.S.A., because it was a property settlement

MARJORIE GELBER, f/k/a MARJORIE GELBER BRYDGER v. GORDON CHARLES BRYDGER

248 So. 3d 1170

District Court of Appeal of Florida | Filed: Jun 6, 2018 | Docket: 7061990

Cited 1 times | Published

maintenance, and alimony agreements or orders, section 61.14(1)(a), Florida Statutes (2017), is primarily

Bruce v. Bruce - corrected 2/5/18

243 So. 3d 461

District Court of Appeal of Florida | Filed: Jan 29, 2018 | Docket: 6300782

Cited 1 times | Published

Florida’s supportive relationship statute, section 61.14(1)(b), Florida Statutes (2015), is not applicable

Randall v. Griffin

204 So. 3d 965, 2016 Fla. App. LEXIS 17105

District Court of Appeal of Florida | Filed: Nov 10, 2016 | Docket: 4540782

Cited 1 times | Published

enforcement provisions should be ordered. See § 61.14(5)(b), Fla. Stat. (2015). Here, the trial court

Haritos v. Haritos

193 So. 3d 1050, 2016 WL 3265499, 2016 Fla. App. LEXIS 9205, 41 Fla. L. Weekly Fed. D 1403

District Court of Appeal of Florida | Filed: Jun 15, 2016 | Docket: 3078604

Cited 1 times | Published

upon entering a final order in a proceeding.” § 61.14(ll)(a). Because the trial court’s jurisdiction

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

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Baratta v. Costa-Martinez

139 So. 3d 407, 2014 WL 2118228, 2014 Fla. App. LEXIS 7719

District Court of Appeal of Florida | Filed: May 21, 2014 | Docket: 60241095

Cited 1 times | Published

pay a $20,000 purge to avoid incarceration. See § 61.14(5)(a), Fla. Stat. (2014) (providing for a presumption

Gregory v. Gregory

128 So. 3d 926, 2013 WL 6687816, 2013 Fla. App. LEXIS 20098

District Court of Appeal of Florida | Filed: Dec 20, 2013 | Docket: 60237217

Cited 1 times | Published

A review of a trial court’s decision under section 61.14(l)(b), Florida Statutes (2012), is a mixed question

Murphy v. Murphy

201 So. 3d 18, 2013 WL 5927542, 2013 Fla. App. LEXIS 17661

District Court of Appeal of Florida | Filed: Nov 6, 2013 | Docket: 60256972

Cited 1 times | Published

“supportive relationship” within the meaning of section 61.14(l)(b), Florida Statutes (2011), and that a reduction

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

Supportive Relationship — a relationship, defined in section 61.14(l)(b)l, Florida Statutes, existing between a

Schecter v. Schecter

109 So. 3d 833, 2013 WL 811625, 2013 Fla. App. LEXIS 3506

District Court of Appeal of Florida | Filed: Mar 6, 2013 | Docket: 60229814

Cited 1 times | Published

Mr. Schecter’s temporary support obligation. Section 61.14(ll)(a), of the Florida Statutes provides that

Mason v. Janssen

113 So. 3d 41, 2012 WL 4039272, 2012 Fla. App. LEXIS 15393

District Court of Appeal of Florida | Filed: Sep 14, 2012 | Docket: 60231552

Cited 1 times | Published

modification would not reach back into the case. See § 61.14(l)(a), Fla. Stat. (2010) (allowing modification

Cook v. Cook

94 So. 3d 683, 2012 WL 3326304, 2012 Fla. App. LEXIS 13549

District Court of Appeal of Florida | Filed: Aug 15, 2012 | Docket: 60310957

Cited 1 times | Published

844 So.2d 691, 693 (Fla. 4th DCA 2003). Under section 61.14, Florida Statutes (2011), statutory modification

Morrell v. Morrell

113 So. 3d 857, 2012 WL 832729, 2012 Fla. App. LEXIS 4093, 37 Fla. L. Weekly Fed. D 621

District Court of Appeal of Florida | Filed: Mar 14, 2012 | Docket: 60231621

Cited 1 times | Published

a payee’s relationship, not to a payor’s. See § 61.14(l)(b)(l), Fla. Stat; (2009) (providing that a court

Hernandez v. Frontiero

73 So. 3d 875, 2011 Fla. App. LEXIS 17788, 2011 WL 5375071

District Court of Appeal of Florida | Filed: Nov 9, 2011 | Docket: 2569485

Cited 1 times | Published

purge himself of any subsequent contempt. See § 61.14(5)(a), Fla. Stat. (2010) ("If the obligor *876

Webber v. Webber

56 So. 3d 822, 2011 Fla. App. LEXIS 582, 2011 WL 252734

District Court of Appeal of Florida | Filed: Jan 28, 2011 | Docket: 60298659

Cited 1 times | Published

filing of a petition seeking a modification. See § 61.14(l)(a), Fla. Stat. (2006) (providing that court

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

59 So. 3d 792, 35 Fla. L. Weekly Supp. 734, 2010 Fla. LEXIS 2116, 2010 WL 5129227

Supreme Court of Florida | Filed: Dec 16, 2010 | Docket: 60299743

Cited 1 times | Published

the beginning *938of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

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

modification might be sought in the future pursuant to section 61.14, Florida Statutes. The issue of permanent periodic

Suarez v. Sanchez

43 So. 3d 118, 2010 Fla. App. LEXIS 12186, 2010 WL 3239168

District Court of Appeal of Florida | Filed: Aug 18, 2010 | Docket: 60295399

Cited 1 times | Published

So.2d 1081, 1082 (Fla. 2d DCA 2006); see also § 61.14(l)(a), Fla. Stat. (2009) (“When the parties enter

Overton v. Overton

34 So. 3d 759, 2010 Fla. App. LEXIS 5888, 2010 WL 1709143

District Court of Appeal of Florida | Filed: Apr 29, 2010 | Docket: 1129330

Cited 1 times | Published

of the recipient's supportive relationship. See § 61.14(1)(b)(1)-(2), Florida Statutes (2007); French v

Schmachtenberg v. Schmachtenberg

34 So. 3d 28, 2010 Fla. App. LEXIS 2098, 2010 WL 624200

District Court of Appeal of Florida | Filed: Feb 24, 2010 | Docket: 1662731

Cited 1 times | Published

the trial court, invested with authority by section 61.14(l)(a), Florida Statutes, made a modification

Baumann v. Baumann

22 So. 3d 719, 2009 Fla. App. LEXIS 16877, 2009 WL 3787768

District Court of Appeal of Florida | Filed: Nov 13, 2009 | Docket: 1176733

Cited 1 times | Published

August 21, 2007, the Former Husband, citing section 61.14(1)(b)(2)(a-k), (3), Florida Statutes (2007)

Rotolante v. Rotolante

22 So. 3d 684, 2009 Fla. App. LEXIS 16558, 2009 WL 3670354

District Court of Appeal of Florida | Filed: Nov 6, 2009 | Docket: 1176878

Cited 1 times | Published

modification of the support amount was warranted under section 61.14, Florida Statutes, as he never requested modification

Kasm v. Lynnel

975 So. 2d 560, 2008 WL 373618

District Court of Appeal of Florida | Filed: Feb 13, 2008 | Docket: 1727189

Cited 1 times | Published

circuit court while the litigation proceeds. See § 61.14(11), Fla. Stat. (2005). If further discovery reveals

Vriesenga v. Vriesenga

931 So. 2d 213, 2006 WL 1627527

District Court of Appeal of Florida | Filed: Jun 14, 2006 | Docket: 1522217

Cited 1 times | Published

maintenance, or alimony provided for in the . . . order. § 61.14(1)(a), Fla. Stat. (2004). Here Mr. Vriesenga has

P.A.G. v. A.F.

602 So. 2d 1259

Supreme Court of Florida | Filed: Jun 11, 1992 | Docket: 64669142

Cited 1 times | Published

order of *1261child support brought pursuant to section 61.14(1). Id. (Gunther, J., dissenting). Based upon

Torres v. Torres

516 So. 2d 11, 1987 WL 1191

District Court of Appeal of Florida | Filed: Nov 5, 1987 | Docket: 1677870

Cited 1 times | Published

motion to transfer. The wife appeals this order. Section 61.14, Florida Statutes (Supp. 1986), provides as

Ibanez v. Salazar

459 So. 2d 346

District Court of Appeal of Florida | Filed: Oct 23, 1984 | Docket: 1282350

Cited 1 times | Published

In reaching our decision, we do not overlook Section 61.14(1), Florida Statutes (1983), relied on by the

Hogshead v. Hogshead

444 So. 2d 74

District Court of Appeal of Florida | Filed: Jan 26, 1984 | Docket: 451988

Cited 1 times | Published

was used in denying the husband's request. Section 61.14(1), Florida Statutes (1981), gives the trial

Haas v. Haas

421 So. 2d 664, 1982 Fla. App. LEXIS 21568

District Court of Appeal of Florida | Filed: Nov 2, 1982 | Docket: 64593131

Cited 1 times | Published

became final except as to the alimony award. See § 61.14 Fla.Stat. (1979). . See Black’s Law Dictionary

Gaddy v. Gaddy

415 So. 2d 37, 1982 Fla. App. LEXIS 19869

District Court of Appeal of Florida | Filed: Apr 29, 1982 | Docket: 64590525

Cited 1 times | Published

evidence to support the trial court’s order. Under Section 61.14, Florida Statutes (1979), the trial judge is

Ruscoe v. Ruscoe

327 So. 2d 93

District Court of Appeal of Florida | Filed: Feb 20, 1976 | Docket: 1716190

Cited 1 times | Published

provision contained in Fla. Stat. § 61.14 (1973) applies. Fla. Stat. § 61.14 provides: "61.14 Modification

Dash v. Dash

306 So. 2d 543

District Court of Appeal of Florida | Filed: Dec 31, 1974 | Docket: 1376876

Cited 1 times | Published

(December 6, 1972), may be filed as provided in Florida Statute 61.14. "It is accordingly, ORDERED and ADJUDGED

Waddell v. Waddell

305 So. 2d 30

District Court of Appeal of Florida | Filed: Dec 3, 1974 | Docket: 1512324

Cited 1 times | Published

petitioner, seeking relief pursuant to Fla. Stat. § 61.14. He appeals an order striking portions of his petition

Nooe v. Nooe

277 So. 2d 835

District Court of Appeal of Florida | Filed: May 11, 1973 | Docket: 1730537

Cited 1 times | Published

"Separate Maintenance" is retained in that law. Section 61.14(1), Florida Statutes, 5 F.S.A. In our opinion

Vance v. Vance

274 So. 2d 5

District Court of Appeal of Florida | Filed: Feb 28, 1973 | Docket: 20617

Cited 1 times | Published

modification of the judgment as provided by Section 61.14, F.S. 1971, F.S.A., as they are advised. See

Schulman v. Schulman

273 So. 2d 403

District Court of Appeal of Florida | Filed: Feb 27, 1973 | Docket: 1512831

Cited 1 times | Published

modification of alimony judgments, Fla. Stat. § 61.14, F.S.A., is broadly written to give the courts

David T. Beans v. Amy S. Beans

District Court of Appeal of Florida | Filed: Apr 30, 2025 | Docket: 69996621

Published

The preceding majority opinion addressed why section 61.14, Florida Statutes—not section 61.08—applies

Stockdale v. Stockdale

District Court of Appeal of Florida | Filed: Apr 9, 2025 | Docket: 69864370

Published

no absolute right to those future payments. See § 61.14, Fla. Stat. (allowing for the modification or termination

Kirby Marbrando Grant, Jr. v. State of Florida, Department of Revenue, Child Support Program and Brittney Nicole Johnson

District Court of Appeal of Florida | Filed: Feb 12, 2025 | Docket: 69632920

Published

age or the disability of nonage is removed. § 61.14(9), Fla. Stat. However, Respondent's obligation

Woodward v. Woodward

District Court of Appeal of Florida | Filed: Jan 22, 2025 | Docket: 69564920

Published

of alimony, if any, to be awarded," and section 61.14(1)(b)1 provides that "[t]he court must

Woodward v. Woodward

District Court of Appeal of Florida | Filed: Jan 22, 2025 | Docket: 69564920

Published

of alimony, if any, to be awarded," and section 61.14(1)(b)1 provides that "[t]he court must

Shirley A. O'Brien v. Eugene J. O'Brien

District Court of Appeal of Florida | Filed: Nov 6, 2024 | Docket: 69347466

Published

in nature.” Nangle, 286 So. 3d at 379; see also § 61.14(1)(a), Fla. Stat. (2023) (providing that a court

Jonathan T. Dwight v. Mary L. Dwight

District Court of Appeal of Florida | Filed: Oct 18, 2024 | Docket: 69274923

Published

change in circumstances or financial ability. § 61.14(1)(a), Fla. Stat. (2022). That same provision authorizes

Rachael Morelli v. Sean J. Bordelon

District Court of Appeal of Florida | Filed: Sep 27, 2024 | Docket: 69204447

Published

the date of the petition for modification. See § 61.14(1)(a), Fla. Stat. (2022); Carmack v. Carmack, 316

Rachael Morelli v. Sean J. Bordelon

District Court of Appeal of Florida | Filed: Sep 27, 2024 | Docket: 69204447

Published

the date of the petition for modification. See § 61.14(1)(a), Fla. Stat. (2022); Carmack v. Carmack, 316

Haslauer v. Haslauer

District Court of Appeal of Florida | Filed: Mar 6, 2024 | Docket: 68313502

Published

bodily attachment to enforce support obligation); § 61.14, Fla. Stat. (providing for modification and enforcement

MARK CIPOLLINA v. JUDITH CIPOLLINA

District Court of Appeal of Florida | Filed: Jan 19, 2024 | Docket: 67068621

Published

157 So. 3d 332, 337-38 (Fla. 2d DCA 2015)). Section 61.14(1)(a), Florida Statutes (2021), provides for

RAYNESSA T. PARRIS v. AZARIAH B. ISRAEL

District Court of Appeal of Florida | Filed: Dec 13, 2023 | Docket: 68083875

Published

support delinquency becomes a final judgment. See § 61.14(6)(d), Fla. Stat. (2023) (providing that when a

Spann v. Payne, S.

District Court of Appeal of Florida | Filed: Dec 13, 2023 | Docket: 68084178

Published

support can be imposed “as equity requires.” See § 61.14(1)(a), Fla. Stat. Mr. Spann therefore properly

DENA SPECTOR v. SETH SPECTOR

District Court of Appeal of Florida | Filed: Oct 11, 2023 | Docket: 67871240

Published

Seth Selesnow (“Mr. Selesnow”), citing to section 61.14, Florida Statutes, which provides for the termination

JOHN-CHARLES ALLAIRE v. BARBARA SILVA ALLAIRE

District Court of Appeal of Florida | Filed: Sep 15, 2023 | Docket: 67229770

Published

change in circumstances in accordance with [section] 61.14."). Former Husband owned an upholstery

EDWARD J. MANGO vs KATHLEEN M. MANGO

District Court of Appeal of Florida | Filed: Sep 1, 2023 | Docket: 66780964

Published

analysis or result. Further, and importantly, section 61.14(1)(a), the language of the statute governing

JACQUELINE GIRARD v. TIMOTHY GIRARD

District Court of Appeal of Florida | Filed: Nov 30, 2022 | Docket: 66575254

Published

upon a substantial change in circumstances”); § 61.14(1)(a), Fla. Stat. (2021) (stating that a court

NICOLE KRAUS v. THOMAS KRAUS

District Court of Appeal of Florida | Filed: Aug 24, 2022 | Docket: 64916758

Published

2017) (internal quotations omitted). Section 61.14, Florida Statutes (2022), “gives an ex-spouse

PHILLIP RODOLPH, SR. v. BETTY A. RODOLPH

District Court of Appeal of Florida | Filed: Jun 17, 2022 | Docket: 63392754

Published

considered in modification proceedings under section 61.14”). Notably, section 61.08(2) requires, among

PHILLIP RODOLPH, SR. v. BETTY A. RODOLPH

District Court of Appeal of Florida | Filed: May 4, 2022 | Docket: 63285683

Published

considered in modification proceedings under section 61.14”). Notably, section 61.08(2) requires, among

SCOTT ALAN ORTH v. MARCY ORTH

District Court of Appeal of Florida | Filed: Mar 30, 2022 | Docket: 63198459

Published

Motion to Enforce v. Motion to Modify under section 61.14 The Former Husband further argues that

GWENDOLYN MONIQUE VALBY v. JOHN CRAIG VALBY

District Court of Appeal of Florida | Filed: Apr 28, 2021 | Docket: 59860112

Published

modification. The wife next argues that section 61.14, Florida Statutes, provides the court with jurisdiction

CRAIG D CARTER, SR. v. LENORA J. CARTER

District Court of Appeal of Florida | Filed: Apr 15, 2020 | Docket: 17070196

Published

arrearages retroactive to the date of separation. Section 61.14(11), Florida Statutes (2016) provides:

THOMAS NANGLE v. MARY NANGLE

District Court of Appeal of Florida | Filed: Dec 18, 2019 | Docket: 16601131

Published

amount of . . . alimony provided in the agreement.” § 61.14(1)(a), Fla. Stat. (2019). A key factor in

TODD KOZEL v. ASHLEY D. KOZEL

District Court of Appeal of Florida | Filed: Nov 27, 2019 | Docket: 16523187

Published

jurisdiction to modify an alimony award under section 61.14). But where these exceptions do not apply—and

PEDRO SUAREZ v. CANDICE MURPHY SUAREZ

District Court of Appeal of Florida | Filed: Nov 13, 2019 | Docket: 16460462

Published

correctly adhered to the statutory requirements of section 61.14, Florida Statutes (2018), and competent and

Gary Lee Knowlton, Former Husband v. Marja-Leena Knowlton, Former Wife

District Court of Appeal of Florida | Filed: Oct 1, 2019 | Docket: 16275553

Published

plain language of section 61.14(7), Florida Statutes (2017). Before 1993, section 61.14, Florida Statutes

BRADLEY ENGLE v. MICHELLE K. ENGLE

District Court of Appeal of Florida | Filed: Jul 3, 2019 | Docket: 15875046

Published

ongoing nature of family proceedings. See generally § 61.14(1)(a) ("[T]he court may modify an order of

Michael E. Holder, Former Husband v. Anna Marie Lopez, f/k/a Anna Marie Holder, Former Wife

274 So. 3d 518

District Court of Appeal of Florida | Filed: Jun 7, 2019 | Docket: 15738277

Published

in evaluating need and ability to pay alimony); § 61.14(1)(a), Fla. Stat. (governing changes in alimony

LUCI ZUBRICKY v. MICHAEL ZUBRICKY

273 So. 3d 217

District Court of Appeal of Florida | Filed: May 15, 2019 | Docket: 15566687

Published

paramour, making her ineligible for alimony under section 61.14, Florida Statutes (2014).

Paulette v. Rosella

267 So. 3d 571

District Court of Appeal of Florida | Filed: Apr 5, 2019 | Docket: 64709251

Published

overlooked controlling Florida law. First, section 61.14(1)(a), Florida Statutes (2017), provides in

Paulette v. Rosella

267 So. 3d 571

District Court of Appeal of Florida | Filed: Apr 5, 2019 | Docket: 64709250

Published

overlooked controlling Florida law. First, section 61.14(1)(a), Florida Statutes (2017), provides in

Silva v. Silva

273 So. 3d 116

District Court of Appeal of Florida | Filed: Feb 13, 2019 | Docket: 64716037

Published

in the father's child support obligation, see § 61.14, Fla. Stat. Affirmed.

Silva v. Silva

273 So. 3d 116

District Court of Appeal of Florida | Filed: Feb 13, 2019 | Docket: 64716038

Published

in the father's child support obligation, see § 61.14, Fla. Stat. Affirmed.

Silva v. Silva

District Court of Appeal of Florida | Filed: Feb 13, 2019 | Docket: 14549569

Published

in the father’s child support obligation, see § 61.14, Fla. Stat. Affirmed.

DANIEL INMAN v. CATHERINE INMAN

260 So. 3d 555

District Court of Appeal of Florida | Filed: Dec 28, 2018 | Docket: 8462506

Published

He alternatively sought modification under section 61.14(1)(a), Florida Statutes (2016), based on the

JASON NUTTLE v. CHRISTINE NUTTLE

257 So. 3d 1084

District Court of Appeal of Florida | Filed: Nov 14, 2018 | Docket: 8186521

Published

the financial ability of the parties . . . . § 61.14(1)(a), Fla. Stat. (2016). In Thyrre v. Thyrre

Shaarbay v. Alvarez

255 So. 3d 487

District Court of Appeal of Florida | Filed: Sep 20, 2018 | Docket: 64689238

Published

PER CURIAM. *488Affirmed. See § 61.14(6)(a)3., Fla. Stat. (2017) ("The judgment under this paragraph

SUSAN LEE MALOWNEY v. JOHN RAPHAEL MALOWNEY

250 So. 3d 204

District Court of Appeal of Florida | Filed: Jun 20, 2018 | Docket: 7225310

Published

additionally alleged bases for modification. See § 61.14(1)(a), Fla. Stat. (2016); see also Wolfe v. Wolfe

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

Supportive Relationship-a relationship, defined in section 61.14(1)(b)1, Florida Statutes, existing between an

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

Supportive Relationship—a relationship, defined in section 61.14(l)(b)l, Florida Statutes, existing between an

Ispass v. Ispass

243 So. 3d 453

District Court of Appeal of Florida | Filed: Jan 29, 2018 | Docket: 6300773

Published

subject matter jurisdiction, reasoning that section 61.14, Florida Statutes (2003), allows the court to

Dogoda v. Dogoda

District Court of Appeal of Florida | Filed: Dec 6, 2017 | Docket: 6236461

Published

the financial ability of the parties . . . . § 61.14(1)(a), Fla. Stat. (2015).

Glenn Robert Broga, Former Husband v. Linda Marie Broga, Former Wife

227 So. 3d 239, 2017 WL 4526769, 2017 Fla. App. LEXIS 14234

District Court of Appeal of Florida | Filed: Oct 11, 2017 | Docket: 6182902

Published

relief on the basis of changed circumstances. See § 61.14, Fla. Stat. (2017). Absent legally sufficient evidence

Kallett v. Kastriner

225 So. 3d 967, 2017 Fla. App. LEXIS 12368, 2017 WL 3721819

District Court of Appeal of Florida | Filed: Aug 30, 2017 | Docket: 6145447

Published

remand for further proceedings pursuant to section 61.14, Florida Statutes (2014). FACTUAL AND PROCEDURAL

Department of Revenue Ex Rel. Tisdale v. Jackson

217 So. 3d 192, 2017 Fla. App. LEXIS 5104

District Court of Appeal of Florida | Filed: Apr 13, 2017 | Docket: 5099897

Published

13(l)(a)l.a., Fla. Stat. (2015); see also § 61.14(9), Fla. Stat. (2016) (“Unless otherwise ordered

Sidney C. Rosenthal v. Gretchen A. Rosenthal

199 So. 3d 541, 2016 Fla. App. LEXIS 13701, 2016 WL 4751758

District Court of Appeal of Florida | Filed: Sep 13, 2016 | Docket: 4425518

Published

least in the absence of parol evidence”). Section 61.14(l)(a), Florida Statutes (2013), allows for the

Department of Revenue v. Juan Llamas and Jennifer Duque

196 So. 3d 1267, 2016 Fla. App. LEXIS 12223, 2016 WL 4446050

District Court of Appeal of Florida | Filed: Aug 4, 2016 | Docket: 4116968

Published

parties.” § 61.13(l)(a)2., Fla. Stat.; see also § 61.14(l)(a), Fla. Stat. (permitting court to order decrease

Bachman v. McLinn

197 So. 3d 123, 2016 Fla. App. LEXIS 11060, 2016 WL 3913366

District Court of Appeal of Florida | Filed: Jul 20, 2016 | Docket: 4112458

Published

costs retroactive to March 2010. See § 61.14(l)(a), Fla. Stat. (2011) (“Except as otherwise

Martin v. Robbins

194 So. 3d 563, 2016 Fla. App. LEXIS 9673, 2016 WL 3458429

District Court of Appeal of Florida | Filed: Jun 24, 2016 | Docket: 3091556

Published

and resides with him or her. § 61.14(l)(b), Fla. Stat. (2015). Section 61.14, Florida Statutes (2015), sets

Pollack v. Pollack

181 So. 3d 1287, 2015 Fla. App. LEXIS 19509, 2015 WL 9491842

District Court of Appeal of Florida | Filed: Dec 31, 2015 | Docket: 60252547

Published

supportive relationship with another person. - See § 61.14(1)(b), Fla, Stat. (2015). The former husband properly

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

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Timmons v. Timmons

179 So. 3d 380, 2015 Fla. App. LEXIS 16135, 2015 WL 6575864

District Court of Appeal of Florida | Filed: Oct 30, 2015 | Docket: 3008639

Published

financially impossible. See, e.g., § 61.14, Fla. Stat. We need not reach the issue of whether

Denise Miggins v. Joseph Miggins

177 So. 3d 315, 2015 Fla. App. LEXIS 15624, 2015 WL 6160651

District Court of Appeal of Florida | Filed: Oct 21, 2015 | Docket: 2991040

Published

supportive relationship” in accordance with section 61.14, Florida Statutes (2014). Affirmed in

Department of Revenue v. Sean Michael Wolf and Christina Lian Guilliams

164 So. 3d 101

District Court of Appeal of Florida | Filed: May 6, 2015 | Docket: 2655231

Published

may be “applicable.” The Department points to section 61.14, entitled “Enforcement and modification of support

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

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Dennis K. Rock v. Department of Revenue

159 So. 3d 287, 2015 Fla. App. LEXIS 3035, 2015 WL 895853

District Court of Appeal of Florida | Filed: Mar 4, 2015 | Docket: 2639011

Published

court’s inactive calendar. [P]ursuant to section 61.14(l)(a), a parent seeking modification of child

Atkinson v. Atkinson

157 So. 3d 473, 2015 Fla. App. LEXIS 1776, 2015 WL 574251

District Court of Appeal of Florida | Filed: Feb 11, 2015 | Docket: 2633533

Published

“supportive relationship” within the meaning of section 61.14(1)(b), Florida Statutes (2011), and that there

Talbert John Wood v. Margaret Blunck

152 So. 3d 693

District Court of Appeal of Florida | Filed: Nov 23, 2014 | Docket: 2608261

Published

527 So.2d 858, 860 (Fla. 1st DCA 1988); § 61.14(1), Fla. Stat. *695 (2009). For example

Ellisen v. Ellisen

150 So. 3d 1270, 2014 Fla. App. LEXIS 19139, 2014 WL 6488839

District Court of Appeal of Florida | Filed: Nov 21, 2014 | Docket: 60244190

Published

So.2d 799, 800-01 (Fla. 3d DCA 1967)); see also § 61.14, Fla. Stat. (2012) (giving former spouses authority

Garvey v. Garvey

138 So. 3d 1115, 2014 WL 1908811, 2014 Fla. App. LEXIS 7112

District Court of Appeal of Florida | Filed: May 14, 2014 | Docket: 60240487

Published

974 (Fla. 4th DCA 2007) (citation omitted). Section 61.14(1)(a), Florida Statutes, governs modification

Horowitz v. Horowitz

139 So. 3d 929, 2014 WL 1908927, 2014 Fla. App. LEXIS 7120

District Court of Appeal of Florida | Filed: May 14, 2014 | Docket: 60241238

Published

modify the alimony and child support awards. See § 61.14(1)(a), Fla. Stat. (2013). He alleged a substantial

In Re: Amendments to Florida Supreme Court Approved Family Law Form

Supreme Court of Florida | Filed: May 1, 2014 | Docket: 57368

Published

supportive relationship in accordance with section 61.14, Florida Statutes. b.____ Bridge-the-Gap

Hoover v. Florida Department of Revenue ex rel. Mitchell

114 So. 3d 494, 2013 WL 2462119, 2013 Fla. App. LEXIS 9238

District Court of Appeal of Florida | Filed: Jun 10, 2013 | Docket: 60231951

Published

under section 409.2564(ll)(b), Florida Statutes. § 61.14(ll)(b). The statute appears to make an award of

Smith v. Smith

110 So. 3d 108, 2013 WL 1136327, 2013 Fla. App. LEXIS 4421

District Court of Appeal of Florida | Filed: Mar 20, 2013 | Docket: 60230162

Published

invoking Florida’s supportive relationship statute section 61.14, Florida Statutes (2011),1 notwithstanding the

Ozuna v. Sheard

109 So. 3d 1176, 2013 WL 1136446, 2013 Fla. App. LEXIS 4433

District Court of Appeal of Florida | Filed: Mar 20, 2013 | Docket: 60229451

Published

jurisdiction to modify the amount of child support. Section 61.14(a), Florida Statutes (2012), specifically permits

Van Looven v. Van Looven

100 So. 3d 148, 2012 WL 4839771, 2012 Fla. App. LEXIS 17614

District Court of Appeal of Florida | Filed: Oct 12, 2012 | Docket: 60225646

Published

the dismissal of Appellant’s petition. Under section 61.14(1)(a), Florida Statutes (2010), a party who

Wiesenfeld v. Wiesenfeld

95 So. 3d 959, 2012 WL 3326298, 2012 Fla. App. LEXIS 13584

District Court of Appeal of Florida | Filed: Aug 15, 2012 | Docket: 60311351

Published

in the former wife’s financial circumstances. § 61.14(1), Fla. Stat. (2010); Pimm v. Pimm, 601 So.2d

Overton v. Overton

92 So. 3d 253, 2012 WL 2138099, 2012 Fla. App. LEXIS 9686

District Court of Appeal of Florida | Filed: Jun 14, 2012 | Docket: 60310177

Published

supportive relationship within the meaning of section 61.14(l)(b), Florida Statutes (2010), the supportive

Brown v. Brown

68 So. 3d 964, 2011 Fla. App. LEXIS 13433, 2011 WL 3760872

District Court of Appeal of Florida | Filed: Aug 26, 2011 | Docket: 2360528

Published

actual reduction in child support. We disagree. Section 61.14(1)(a), Florida Statutes (2009), gives the trial

Morrison v. Morrison

60 So. 3d 410, 2011 Fla. App. LEXIS 1575, 2011 WL 478711

District Court of Appeal of Florida | Filed: Feb 11, 2011 | Docket: 60300202

Published

to decrease or increase the amount of alimony. § 61.14(l)(a), Fla. Stat. (2006); Bedell v. Bedell, 583

Delate v. Iler

50 So. 3d 1242, 2011 Fla. App. LEXIS 695, 2011 WL 222214

District Court of Appeal of Florida | Filed: Jan 26, 2011 | Docket: 60297275

Published

2d 1081, 1082 (Fla. 2d DCA 2006), and citing section 61.14, Florida Statutes). Affirmed. WARNER, POLEN

In Re Amend. to the Fla. Family Law Forms

59 So. 3d 792

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

Published

the beginning *938 of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

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

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Morris v. Morris

42 So. 3d 341, 2010 Fla. App. LEXIS 12202, 2010 WL 3269238

District Court of Appeal of Florida | Filed: Aug 20, 2010 | Docket: 1449241

Published

court, after using the criteria set forth in section 61.14(1)(b)2., Florida Statutes (2007), to find a

Vollmer v. Vollmer

33 So. 3d 67, 2010 Fla. App. LEXIS 2687, 2010 WL 743934

District Court of Appeal of Florida | Filed: Mar 5, 2010 | Docket: 1156471

Published

recalculate its modification of child support. See § 61.14(1); Hudson-McCann v. McCann, 8 So.3d 1228, 1230

Stewart v. Stewart

976 So. 2d 1224, 2008 WL 783300

District Court of Appeal of Florida | Filed: Mar 26, 2008 | Docket: 2586583

Published

of a substantial change in circumstances. See § 61.14, Fla. Stat. (2005); Woolf v. Woolf, 901 So.2d 905

Benitez v. Benitez

976 So. 2d 75, 2008 WL 373239

District Court of Appeal of Florida | Filed: Feb 13, 2008 | Docket: 2557931

Published

the Husband to the Wife whether pursuant to Section 61.14[,] Florida Statutes[,] or any other provision

Smith v. Smith

932 So. 2d 588, 2006 Fla. App. LEXIS 10779, 2006 WL 1787993

District Court of Appeal of Florida | Filed: Jun 30, 2006 | Docket: 64845613

Published

part) (“Florida courts uniformly agree that section 61.14(1), Florida Statutes, does not allow modification

Mani v. Mani

927 So. 2d 1087, 2006 Fla. App. LEXIS 7760, 2006 WL 1328952

District Court of Appeal of Florida | Filed: May 17, 2006 | Docket: 64844499

Published

has been established as a Florida judgment. See § 61.14(l)(a), Fla. Stat. (2004); Sackler v. Sackler, 47

Hillier v. Iglesias

901 So. 2d 947, 2005 WL 1026174

District Court of Appeal of Florida | Filed: May 4, 2005 | Docket: 378113

Published

the parties. Canakaris, 382 So.2d at 1201. Section 61.14 governs the modification of alimony awards,

Lamar v. Lamar

889 So. 2d 983, 2004 Fla. App. LEXIS 19673, 2004 WL 2952755

District Court of Appeal of Florida | Filed: Dec 22, 2004 | Docket: 64835183

Published

support and to purge himself of the contempt. See § 61.14(5)(a), Fla. Stat. (2003); Bowen v. Bowen, 471 So

Lamar v. Lamar

889 So. 2d 983, 2004 Fla. App. LEXIS 19673, 2004 WL 2952755

District Court of Appeal of Florida | Filed: Dec 22, 2004 | Docket: 64835183

Published

support and to purge himself of the contempt. See § 61.14(5)(a), Fla. Stat. (2003); Bowen v. Bowen, 471 So

Henderson v. Henderson

882 So. 2d 499, 2004 Fla. App. LEXIS 13816, 2004 WL 2098389

District Court of Appeal of Florida | Filed: Sep 22, 2004 | Docket: 64832569

Published

P. 12.190; Fla. R. Civ. P. 1.190(c). See also § 61.14(l)(a), Fla. Stat. (2003) (“[T]he court may modify

Spooner v. Spooner

838 So. 2d 1202, 2003 Fla. App. LEXIS 882, 2003 WL 202391

District Court of Appeal of Florida | Filed: Jan 31, 2003 | Docket: 64821036

Published

the ambit of rules 1.540 and 12.540. Rather, section 61.14(l)(a), Florida Statutes (1999), which does not

Brown v. Brown

825 So. 2d 519, 2002 Fla. App. LEXIS 13206, 2002 WL 31026843

District Court of Appeal of Florida | Filed: Sep 12, 2002 | Docket: 64817336

Published

1997). Such a ruling was not compelled under section 61.14(5)(a) with regard to the current support obligation

Ruiz v. Ruiz

821 So. 2d 1112, 2002 Fla. App. LEXIS 8212, 2002 WL 1285100

District Court of Appeal of Florida | Filed: Jun 12, 2002 | Docket: 64816507

Published

Husband’s present ability to pay as required by Section 61.14(5)(a), Florida Statutes, and in failing to consider

Roll v. Roll

812 So. 2d 529

District Court of Appeal of Florida | Filed: Mar 27, 2002 | Docket: 64813879

Published

Jenne, 721 So.2d 380, 383 (Fla. 4th DCA 1998); § 61.14, Fla. Stat. (2000). Here, the court did not consider

Foti v. Camejo

812 So. 2d 507, 2002 Fla. App. LEXIS 3559, 2002 WL 427715

District Court of Appeal of Florida | Filed: Mar 20, 2002 | Docket: 64813870

Published

residency. See § 61.13(l)(a), Fla. Stat. (2001); § 61.14(1), Fla. Stat. (2001); Vero v. Vero, 659 So.2d

Flores v. Bieluch

814 So. 2d 448, 2001 Fla. App. LEXIS 16062, 2001 WL 1418633

District Court of Appeal of Florida | Filed: Nov 14, 2001 | Docket: 64814491

Published

As well, Pompey was based on law prior to section 61.14(5)(a), Florida Statutes, which controls the

Albright v. Albright

788 So. 2d 1125, 2001 Fla. App. LEXIS 9519, 2001 WL 770036

District Court of Appeal of Florida | Filed: Jul 11, 2001 | Docket: 64806564

Published

AFFIRMED. SHAHOOD and HAZOURI, JJ., concur. . Section 61.14(5)(a), Florida Statutes (2000), provides in

Dziuba v. Dziuba

784 So. 2d 1192, 2001 Fla. App. LEXIS 4738, 2001 WL 356240

District Court of Appeal of Florida | Filed: Apr 11, 2001 | Docket: 64805323

Published

modifying the final judgment, we hold that section 61.14, Florida Statutes (1999), allows a trial court

Knapp v. Knapp

778 So. 2d 475, 2001 Fla. App. LEXIS 1782, 2001 WL 167276

District Court of Appeal of Florida | Filed: Feb 21, 2001 | Docket: 64803787

Published

Therefore, the trial judge denied modification. Section 61.14, Florida Statutes (1999) provides: Enforcement

Mingione v. Mingione

756 So. 2d 197, 2000 WL 369344

District Court of Appeal of Florida | Filed: Apr 12, 2000 | Docket: 471273

Published

applied. The former husband had relied on section 61.14, a more particular statute which provides inter

Amendments to the Florida Family Law Forms

759 So. 2d 583, 24 Fla. L. Weekly Supp. 321, 1999 Fla. LEXIS 1174, 1999 WL 462636

Supreme Court of Florida | Filed: Jul 1, 1999 | Docket: 64797771

Published

found at the beginning of these forms. See also section 61.14, Florida Statutes and rule 12.615, Florida Family

Blackwelder v. Vedder

734 So. 2d 523, 1999 Fla. App. LEXIS 6703, 1999 WL 326317

District Court of Appeal of Florida | Filed: May 21, 1999 | Docket: 64788601

Published

ability to purge himself from the contempt. See § 61.14(5)(a), Fla. Stat. (1997). The trial judge was openly

Roshkind v. Roshkind

717 So. 2d 545, 1998 Fla. App. LEXIS 8002, 1998 WL 348364

District Court of Appeal of Florida | Filed: Jul 1, 1998 | Docket: 64782785

Published

a modification within the meaning of either section 61.14, Florida Statutes (1995), or case law. We agree

Berthold v. State

709 So. 2d 207, 1998 Fla. App. LEXIS 5528, 1998 WL 241286

District Court of Appeal of Florida | Filed: May 15, 1998 | Docket: 64780176

Published

proceeding was properly given. It also noted that section 61.14(5)(a), Florida Statutes (1997), creates a presumption

Mackay v. Mechetti

695 So. 2d 472, 1997 Fla. App. LEXIS 6251, 1997 WL 309984

District Court of Appeal of Florida | Filed: Jun 11, 1997 | Docket: 64774218

Published

v. Chovnick, 369 So.2d 355 (Fla. 2d DCA 1979); § 61.14(1), Fla. Stat. (Supp.1992). Reversed and remanded

Apa v. Apa

693 So. 2d 702, 1997 Fla. App. LEXIS 5409, 1997 WL 256478

District Court of Appeal of Florida | Filed: May 16, 1997 | Docket: 64773467

Published

application of the presumption articulated in section 61.14(5)(a), Fla. Stat. (1995). However our review

Thompson v. Plowmaker

679 So. 2d 864, 1996 Fla. App. LEXIS 14322, 1996 WL 525858

District Court of Appeal of Florida | Filed: Sep 18, 1996 | Docket: 64767468

Published

dissolution was entered in 1994. We reverse. Section 61.14, Florida Statutes (1995) provides that petitions

Hollander v. Vetrick

675 So. 2d 1047, 1996 Fla. App. LEXIS 6899, 1996 WL 366331

District Court of Appeal of Florida | Filed: Jul 3, 1996 | Docket: 64765551

Published

that issue was never addressed. We note that section 61.14(5), Florida Statutes (Supp.1992), provides that

Ago

Florida Attorney General Reports | Filed: Jun 25, 1996 | Docket: 3258566

Published

for unpaid child support payments provided in section 61.14(6), Florida Statutes, to be recorded? In sum:

Troyer v. Gordon

670 So. 2d 1102, 1996 Fla. App. LEXIS 2673, 1996 WL 125712

District Court of Appeal of Florida | Filed: Mar 22, 1996 | Docket: 64763490

Published

actual present ability to comply with the order.” § 61.14(5)(a), Fla.Stat. (1995). This order does neither

Antoniak v. Antoniak

652 So. 2d 943, 1995 Fla. App. LEXIS 3307, 1995 WL 137080

District Court of Appeal of Florida | Filed: Mar 31, 1995 | Docket: 64755236

Published

reminded that contempt findings are required by section 61.14, Florida Statutes (Supp.1992). (“The court shall

Pratt v. Pratt

645 So. 2d 510, 1994 WL 583942

District Court of Appeal of Florida | Filed: Oct 26, 1994 | Docket: 1223259

Published

by the trial court through an amendment to section 61.14, Florida Statutes (1993), which states that

Racond v. Racond

627 So. 2d 1329, 1993 Fla. App. LEXIS 12368, 1993 WL 517218

District Court of Appeal of Florida | Filed: Dec 14, 1993 | Docket: 64744691

Published

the agreement upon his retirement pursuant to section 61.14, Florida Statutes (1991). Affirmed.

Mederos v. Selph (L.T.), Inc.

625 So. 2d 894, 1993 Fla. App. LEXIS 10095, 1993 WL 393633

District Court of Appeal of Florida | Filed: Oct 8, 1993 | Docket: 64743565

Published

*895support after the 1988 amendment repealing section 61.14(5)(c), Florida Statutes (1987). The 1987 statutes

Department of Health & Rehabilitative Services v. Beckwith

624 So. 2d 395, 1993 Fla. App. LEXIS 9516, 1993 WL 372165

District Court of Appeal of Florida | Filed: Sep 24, 1993 | Docket: 64742998

Published

dismissed, 478 So.2d 53 (Fla.1985). See also § 61.14(5), Fla.Stat. (1991). Accordingly, we hold that

Whitney v. Whitney

624 So. 2d 275, 1993 Fla. App. LEXIS 7614, 1993 WL 267523

District Court of Appeal of Florida | Filed: Jul 20, 1993 | Docket: 64742955

Published

circumstances or the financial ability of the part[y]_” § 61.14(1), Fla.Stat. (1991). A review of Mr. Whitney’s

Compagnoni v. Compagnoni

619 So. 2d 450, 1993 Fla. App. LEXIS 6158, 1993 WL 191942

District Court of Appeal of Florida | Filed: Jun 8, 1993 | Docket: 64696617

Published

Reversed and remanded. . Effective July 1, 1992, section 61.14, Florida Statutes (Supp.1992) provides, in part:

Washington v. Washington

613 So. 2d 594, 1993 Fla. App. LEXIS 1653

District Court of Appeal of Florida | Filed: Feb 12, 1993 | Docket: 64694003

Published

venue is proper in Seminole County, pursuant to section 61.14(1), Florida Statutes. We agree and reverse.

Schafroth v. Schafroth

610 So. 2d 649, 1992 Fla. App. LEXIS 13221, 1992 WL 367339

District Court of Appeal of Florida | Filed: Dec 15, 1992 | Docket: 64692835

Published

it embodied an erroneous conclusion of law. See § 61.14, Fla.Stat. (1991); Feldman v. Feldman, 317 So.2d

Hernandez v. Marsarm Corp.

613 So. 2d 914, 1992 Fla. App. LEXIS 12352, 1992 WL 360943

District Court of Appeal of Florida | Filed: Dec 8, 1992 | Docket: 64694090

Published

Chapter 61, Florida Statutes, and specifically § 61.14 (Enforcement and modification of support, maintenance

Keel v. Keel

597 So. 2d 433, 1992 Fla. App. LEXIS 4650, 1992 WL 81435

District Court of Appeal of Florida | Filed: Apr 24, 1992 | Docket: 64666784

Published

the former Wife has the greater net worth. Section 61.14, Florida Statutes, authorizes the trial court

Mouton v. Mouton

590 So. 2d 40, 1991 Fla. App. LEXIS 12123, 1991 WL 256229

District Court of Appeal of Florida | Filed: Dec 4, 1991 | Docket: 64663500

Published

judgment was arguably no longer executory. Section 61.14, Florida Statutes (1989), extends jurisdiction

Edgar v. Edgar

588 So. 2d 1092, 1991 Fla. App. LEXIS 11852, 1991 WL 247466

District Court of Appeal of Florida | Filed: Nov 26, 1991 | Docket: 64662921

Published

time of the obviously inadequate agreement, see § 61.14(1), Fla.Stat. (1989); Siegel v. Zimmerman, 319

Sheeder v. Sheeder

570 So. 2d 361, 1990 Fla. App. LEXIS 8289, 1990 WL 164823

District Court of Appeal of Florida | Filed: Oct 30, 1990 | Docket: 64654659

Published

the time of the final judgment of dissolution. § 61.14(1), Fla.Stat. (1989). The cause is remanded with

Twomey v. Twomey

566 So. 2d 362, 1990 Fla. App. LEXIS 6748, 1990 WL 129101

District Court of Appeal of Florida | Filed: Sep 5, 1990 | Docket: 64652722

Published

trial court order and remand for dismissal. See section 61.14, Fla.Stat.; Wright v. Wright, 559 So.2d 1193

Bryant v. Bryant

566 So. 2d 65, 1990 Fla. App. LEXIS 6509, 1990 WL 125115

District Court of Appeal of Florida | Filed: Aug 30, 1990 | Docket: 64652658

Published

So.2d 348, 350 (Fla. 1st DCA 1980) stated: “Section 61.14 may not be manipulated to escape or ignore enforcement

P.A.G. v. A.F.

564 So. 2d 266, 1990 Fla. App. LEXIS 5284, 1990 WL 102701

District Court of Appeal of Florida | Filed: Jul 25, 1990 | Docket: 64651675

Published

an order of child support brought pursuant to § 61.14(1). The fact that the order for child support was

Wright v. Wright

559 So. 2d 1193, 1990 Fla. App. LEXIS 1224, 1990 WL 17513

District Court of Appeal of Florida | Filed: Mar 1, 1990 | Docket: 64649742

Published

jurisdiction to grant such relief pursuant to section 61.14, whether or not the original court expressly

Attorney General of Florida ex rel. State v. D'Agosto

541 So. 2d 167, 14 Fla. L. Weekly 911, 1989 Fla. App. LEXIS 1882, 1989 WL 33953

District Court of Appeal of Florida | Filed: Apr 12, 1989 | Docket: 64641494

Published

LETTS, Judge. The lower court held section 61.14, Florida Statutes (1987), unconstitutional because

Tonkin v. Sonnenberg

539 So. 2d 1143, 14 Fla. L. Weekly 475, 1989 Fla. App. LEXIS 687, 1989 WL 11605

District Court of Appeal of Florida | Filed: Feb 16, 1989 | Docket: 64641045

Published

jurisdiction) either in Pinellas or Brevard county. § 61.14; § 61.17, Fla. Stat. (1985). All circuit courts

Mitchell v. Mitchell

536 So. 2d 1107, 13 Fla. L. Weekly 2704, 1988 Fla. App. LEXIS 5506, 1988 WL 131594

District Court of Appeal of Florida | Filed: Dec 14, 1988 | Docket: 64639619

Published

agreement, was subject to modification pursuant to section 61.14, Florida Statutes (1985). See Pujals v. Pujals

Clark v. Render

530 So. 2d 437, 13 Fla. L. Weekly 2004, 1988 Fla. App. LEXIS 4009, 1988 WL 89227

District Court of Appeal of Florida | Filed: Aug 30, 1988 | Docket: 64636706

Published

child-support determinations. Accordingly, section 61.14(1), Florida Statutes (1987), provides: “[T]he

Ago

Florida Attorney General Reports | Filed: Aug 25, 1988 | Docket: 3256927

Published

to July 1, 1987, pursuant to such amendment. Section 61.14, F.S., relates to the enforcement and modification

Best v. State, Department of Health & Rehabilitative Services, Office of Child Support Services ex rel. Donaldson

528 So. 2d 532, 13 Fla. L. Weekly 1749, 1988 Fla. App. LEXIS 3326, 1988 WL 74809

District Court of Appeal of Florida | Filed: Jul 20, 1988 | Docket: 64636043

Published

automatic reduction of the support payment. See § 61.14, Fla.Stat. (1987); Lee v. Lee, 157 Fla. 439, 26

Fox v. Fox

528 So. 2d 81, 13 Fla. L. Weekly 1598, 1988 Fla. App. LEXIS 2924, 1988 WL 69396

District Court of Appeal of Florida | Filed: Jul 6, 1988 | Docket: 64635881

Published

substantial change m circumstances had occurred. See § 61.14, Fla.Stat. Another allegation in the wife’s petition

Robbins v. Robbins

526 So. 2d 1053, 13 Fla. L. Weekly 1456, 1988 Fla. App. LEXIS 2559, 1988 WL 62015

District Court of Appeal of Florida | Filed: Jun 21, 1988 | Docket: 64635498

Published

County is reversed upon a holding that (1) under Section 61.14(1), Florida Statutes (1987), the appellant-wife

Fahs v. Fahs

517 So. 2d 136, 13 Fla. L. Weekly 115, 1987 Fla. App. LEXIS 11818, 1987 WL 29159

District Court of Appeal of Florida | Filed: Dec 31, 1987 | Docket: 64631670

Published

true alimony, and thus modifiable pursuant to section 61.14(1), Florida Statutes (1985), it was error for

Hendricks v. Hendricks

515 So. 2d 1025, 12 Fla. L. Weekly 2479, 1987 Fla. App. LEXIS 10716, 1987 WL 4062

District Court of Appeal of Florida | Filed: Oct 27, 1987 | Docket: 64631029

Published

agreement, was subject to modification pursuant to section 61.14, Florida Statutes (1985). See Pujáis v. Pujáis

Stevens v. Stevens

510 So. 2d 332, 12 Fla. L. Weekly 1521, 1987 Fla. App. LEXIS 8905

District Court of Appeal of Florida | Filed: Jun 19, 1987 | Docket: 64628561

Published

property settlement agreements are non-modifiable. § 61.14, Fla.Stat. (1985); Salomon v. Salomon, 196 So.2d

Paulk v. Paulk

504 So. 2d 790, 12 Fla. L. Weekly 901, 1987 Fla. App. LEXIS 7430

District Court of Appeal of Florida | Filed: Apr 1, 1987 | Docket: 64626074

Published

years after the date of the final judgment. Section 61.14, Florida Statutes, provides that when a party

Horvath v. Horvath

502 So. 2d 475, 12 Fla. L. Weekly 376, 1987 Fla. App. LEXIS 6474

District Court of Appeal of Florida | Filed: Jan 27, 1987 | Docket: 64625031

Published

proceedings, Fort v. Fort, 90 So.2d 313 (Fla.1956); § 61.14, Fla.Stat. (1981); see Underwood v. Underwood,

Smith v. Smith

498 So. 2d 483, 11 Fla. L. Weekly 2178, 1986 Fla. App. LEXIS 10102

District Court of Appeal of Florida | Filed: Oct 15, 1986 | Docket: 64623455

Published

final judgment of dissolution of marriage under Section 61.14, Florida Statutes (1985).

Stein v. Stein

496 So. 2d 196, 11 Fla. L. Weekly 2161, 1986 Fla. App. LEXIS 10060

District Court of Appeal of Florida | Filed: Oct 14, 1986 | Docket: 64622360

Published

child support on November 18, 1985 pursuant to section 61.14, Florida Statutes (1985). After considering

Monihon v. Monihon

492 So. 2d 775, 11 Fla. L. Weekly 1731, 1986 Fla. App. LEXIS 9242

District Court of Appeal of Florida | Filed: Aug 6, 1986 | Docket: 64621021

Published

Brown, 338 So.2d 916 (Fla. 2d DCA 1976); Elkins; § 61.14, Fla.Stat. (1983). Here, the husband had completely

Carr v. Carr

489 So. 2d 889, 11 Fla. L. Weekly 1327, 1986 Fla. App. LEXIS 8360

District Court of Appeal of Florida | Filed: Jun 13, 1986 | Docket: 64619940

Published

judgment, and the special venue provision, Section 61.14, Florida Statutes, to a modification of a support

Goldsmith v. Goldsmith

487 So. 2d 332, 11 Fla. L. Weekly 755

District Court of Appeal of Florida | Filed: Apr 1, 1986 | Docket: 1797653

Published

filing a petition for modification pursuant to Section 61.14, Florida Statutes. Mahaffey v. Harper, supra;

Harvey v. Mattes

484 So. 2d 1382, 11 Fla. L. Weekly 699, 1986 Fla. App. LEXIS 6962

District Court of Appeal of Florida | Filed: Mar 20, 1986 | Docket: 64618043

Published

modification of a divorce decree in the face of section 61.14 which specifically dealt with modification of

Wilson v. Wilson

485 So. 2d 20, 11 Fla. L. Weekly 664, 1986 Fla. App. LEXIS 6937

District Court of Appeal of Florida | Filed: Mar 12, 1986 | Docket: 64618059

Published

determination to end the health and accident coverage. Section 61.14, Florida Statutes (1985), empowers trial courts

Urbanek v. Urbanek

484 So. 2d 595

District Court of Appeal of Florida | Filed: Jan 22, 1986 | Docket: 64617868

Published

its incorporation into the final judgment. Section 61.14(1), Florida Statutes, provides: Modification

Pacinelli v. Pacinelli

480 So. 2d 1360, 1985 Fla. App. LEXIS 17381

District Court of Appeal of Florida | Filed: Dec 17, 1985 | Docket: 64616548

Published

Paras v. Paras, 262 So.2d 203 (Fla. 4th DCA 1972); § 61.14, Fla.Stat. (1983).

Oguz v. Oguz

478 So. 2d 437, 10 Fla. L. Weekly 2513, 1985 Fla. App. LEXIS 16875

District Court of Appeal of Florida | Filed: Nov 7, 1985 | Docket: 64615495

Published

Hogshead, 444 So.2d 74 (Fla. 5th DCA 1984). Section 61.14, Florida Statutes (1983) applies to all such

Diette v. Diette

471 So. 2d 1372, 10 Fla. L. Weekly 1672, 1985 Fla. App. LEXIS 14120

District Court of Appeal of Florida | Filed: Jul 5, 1985 | Docket: 64612881

Published

jurisdiction to terminate or modify alimony awards. § 61.14(1), Fla.Stat.(1981). Appellant is incorrect when

Norwood v. Norwood

466 So. 2d 5, 1985 Fla. App. LEXIS 14084, 10 Fla. L. Weekly 485

District Court of Appeal of Florida | Filed: Feb 21, 1985 | Docket: 64610873

Published

modification is requested and supported by the evidence. § 61.14, Fla.Stat. (1983); Lewis v. Lewis, 450 So.2d 1123

Carr v. Carr

464 So. 2d 221, 10 Fla. L. Weekly 463, 1985 Fla. App. LEXIS 12585

District Court of Appeal of Florida | Filed: Feb 20, 1985 | Docket: 64610172

Published

fall under the special venue provisions of Section 61.14, Florida Statutes, relating to modification

Marriage of Anderson v. Anderson

438 So. 2d 510, 1983 Fla. App. LEXIS 24454

District Court of Appeal of Florida | Filed: Sep 29, 1983 | Docket: 64599840

Published

to obtaining additional alimony pursuant to Section 61.14, Florida Statutes (1975). A spouse who is behind

Owen v. Owen

427 So. 2d 264, 1983 Fla. App. LEXIS 20810

District Court of Appeal of Florida | Filed: Feb 16, 1983 | Docket: 64595266

Published

Florida Rule of Civil Procedure 1.110(h) and Section 61.14, Florida Statutes (1981). Such an order does

Saulnier v. Saulnier

425 So. 2d 558, 1982 Fla. App. LEXIS 22264

District Court of Appeal of Florida | Filed: Dec 8, 1982 | Docket: 64594719

Published

petition for modification filed pursuant to section 61.14, Florida Statutes *559(1979). We find no authority

Trimble v. Trimble

418 So. 2d 441, 1982 Fla. App. LEXIS 20998

District Court of Appeal of Florida | Filed: Aug 24, 1982 | Docket: 64591808

Published

circumstances so as to withstand a motion to dismiss. § 61.14, Fla.Stat. (1981); 25 Fla.Jur.2d Family Law § 483

Sitzer v. Sitzer

417 So. 2d 308, 1982 Fla. App. LEXIS 20732

District Court of Appeal of Florida | Filed: Jul 27, 1982 | Docket: 64591367

Published

amount of alimony or support as equity requires. § 61.14, Fla.Stat. (1979); see Pujals v. Pujals, 414 So

Prout v. Prout

415 So. 2d 905, 1982 Fla. App. LEXIS 20480

District Court of Appeal of Florida | Filed: Jun 29, 1982 | Docket: 64590759

Published

We disagree and reverse. By the enactment of Section 61.14, Florida Statutes (1979), the Legislature has

Stephenson v. Stephenson

408 So. 2d 730, 1982 Fla. App. LEXIS 18882

District Court of Appeal of Florida | Filed: Jan 12, 1982 | Docket: 64587321

Published

v. Lee, 157 Fla. 439, 26 So.2d 177 (1946). Section 61.14, Florida Statutes (1979), provides the parties

Mahaffey v. Harper

405 So. 2d 1070, 1981 Fla. App. LEXIS 21638

District Court of Appeal of Florida | Filed: Nov 18, 1981 | Docket: 64586086

Published

did not petition the court in accordance with Section 61.14, Florida Statutes (1980) for a modification

Fahey v. Fahey

404 So. 2d 423, 1981 Fla. App. LEXIS 21304

District Court of Appeal of Florida | Filed: Oct 13, 1981 | Docket: 64585404

Published

the parties may warrant. Florida Statutes, Section 61.14. BOOTH, LARRY G. SMITH, and SHIVES, JJ., concur

Purex Corp. v. Fay

400 So. 2d 1021, 1981 Fla. App. LEXIS 20268

District Court of Appeal of Florida | Filed: Jun 26, 1981 | Docket: 64583821

Published

benefits, .... (Larson’s Workmen’s Compensation Law, § 61.14) Florida is among the jurisdictions following the

Porter v. Porter

401 So. 2d 832, 1981 Fla. App. LEXIS 21249

District Court of Appeal of Florida | Filed: Jun 18, 1981 | Docket: 64584139

Published

modification of child support by virtue of Section 61.14, Florida Statutes. However, irrespective of

Weiner v. Weiner

386 So. 2d 1251, 1980 Fla. App. LEXIS 17473

District Court of Appeal of Florida | Filed: Jul 29, 1980 | Docket: 64577757

Published

aid in a modification proceeding pursuant to Section 61.14, Florida Statutes (1979). To increase the wife’s

McLean v. McLean

384 So. 2d 915, 1980 Fla. App. LEXIS 16910

District Court of Appeal of Florida | Filed: Jun 10, 1980 | Docket: 64576691

Published

modification upon a timely and proper showing under Section 61.14, Florida Statutes (1979). Cantor v. Cantor,

McIntyre v. McIntyre

380 So. 2d 1195, 1980 Fla. App. LEXIS 15676

District Court of Appeal of Florida | Filed: Mar 12, 1980 | Docket: 64574866

Published

judge who was a stranger to the original suit. Section 61.14, Florida Statutes (1977), authorizes modification

Hirsch v. Hirsch

369 So. 2d 407, 1979 Fla. App. LEXIS 14705

District Court of Appeal of Florida | Filed: Apr 3, 1979 | Docket: 64569474

Published

only a significant “change of circumstances.” Section 61.14(1) Florida Statutes (1975). In contrast, New

Chovnick v. Chovnick

369 So. 2d 355, 1979 Fla. App. LEXIS 14187

District Court of Appeal of Florida | Filed: Feb 23, 1979 | Docket: 64569454

Published

prejudice when she refused to amend further. Section 61.14(1), Fla.Stat. (1977) provides: When the parties

Langlois v. Langlois

365 So. 2d 179, 1978 Fla. App. LEXIS 17102

District Court of Appeal of Florida | Filed: Nov 21, 1978 | Docket: 64567476

Published

to justify the termination of support under Section 61.14, Florida Statutes (1977), where the husband

Kelly v. Kelly

361 So. 2d 428, 1978 Fla. App. LEXIS 15856

District Court of Appeal of Florida | Filed: Jun 21, 1978 | Docket: 64565607

Published

jurisdiction is derived from our reading of Section 61.14(1) of the Florida Statutes, (1977) although

Goerlich v. Goerlich

358 So. 2d 895, 1978 Fla. App. LEXIS 15642

District Court of Appeal of Florida | Filed: May 17, 1978 | Docket: 64564469

Published

subject to modification under certain conditions. Section 61.14, Florida Statutes (1977) authorizes the modification

Willey v. Willey

354 So. 2d 472

District Court of Appeal of Florida | Filed: Jan 31, 1978 | Docket: 64562523

Published

Taplin, 341 So.2d 1064 (Fla.3d DCA 1977); Section 61.14(1), Florida Statutes (1975). Reversed.

Willey v. Willey

354 So. 2d 472

District Court of Appeal of Florida | Filed: Jan 31, 1978 | Docket: 64562523

Published

Taplin, 341 So.2d 1064 (Fla.3d DCA 1977); Section 61.14(1), Florida Statutes (1975). Reversed.

Krieger v. Krieger

344 So. 2d 1346, 1977 Fla. App. LEXIS 15747

District Court of Appeal of Florida | Filed: May 3, 1977 | Docket: 64558212

Published

may of course make application pursuant to Section 61.14 to the trial court for modification of the alimony

Kippert v. Kippert

327 So. 2d 97, 1976 Fla. App. LEXIS 14648

District Court of Appeal of Florida | Filed: Feb 25, 1976 | Docket: 64552547

Published

would always be open to consider this matter. See: § 61.14, Fla.Stat.). We also see no reason for the trial

Hernandez v. Hernandez

325 So. 2d 483, 1976 Fla. App. LEXIS 15278

District Court of Appeal of Florida | Filed: Jan 27, 1976 | Docket: 64551980

Published

vacate the “husband’s home.” We hold that Fla.Stat. § 61.14 authorizes the consideration of the wife’s petition

Anderson v. Anderson

317 So. 2d 458, 1975 Fla. App. LEXIS 14093

District Court of Appeal of Florida | Filed: Jul 30, 1975 | Docket: 64548648

Published

change in circumstances at some future date. (See F.S. 61.14(1)) Anticipated future changes in the circumstances

Feldman v. Feldman

317 So. 2d 136

District Court of Appeal of Florida | Filed: Jul 22, 1975 | Docket: 1315915

Published

Subsequently, in November 1973, Al Feldman, pursuant to § 61.14, Fla. Stat., F.S.A. filed a petition for modification

Dunson v. Dunson

311 So. 2d 189, 1975 Fla. App. LEXIS 13894

District Court of Appeal of Florida | Filed: Apr 10, 1975 | Docket: 64545761

Published

subject to modification by the trial judge, Florida Statute 61.14(1). The appeal is frivolous and is hereby

Quinn v. Quinn

307 So. 2d 848, 1975 Fla. App. LEXIS 14651

District Court of Appeal of Florida | Filed: Feb 7, 1975 | Docket: 64544357

Published

claims this was error, and we agree. Fla.Stat. § 61.14 (1973) which relates to the modification of alimony

Yagoda v. Klein

305 So. 2d 29, 1974 Fla. App. LEXIS 7365

District Court of Appeal of Florida | Filed: Dec 3, 1974 | Docket: 64543315

Published

modification of the alimony payments under Fla.Stat. § 61.14, F.S.A. upon the grounds that the parties had experienced

Bock v. Bock

302 So. 2d 774

District Court of Appeal of Florida | Filed: Nov 1, 1974 | Docket: 64542366

Published

uncover the changed circumstances contemplated by Section 61.14, Florida Statutes, to warrant a modification

Gobelman v. Gobelman

303 So. 2d 646, 1974 Fla. App. LEXIS 8334

District Court of Appeal of Florida | Filed: Oct 17, 1974 | Docket: 64542815

Published

or circumstances occurs to warrant relief. F.S. § 61.14(1). In affirming this portion of the order below

Lockhart v. Lockhart

293 So. 2d 754, 1974 Fla. App. LEXIS 7659

District Court of Appeal of Florida | Filed: May 7, 1974 | Docket: 64538671

Published

Stamm, Fla.App. 1972, 266 So.2d 413; Fla.Stat. § 61.14, F. S.A. For the reasons stated, the order appealed

Plevy v. Plevy

295 So. 2d 139, 1974 Fla. App. LEXIS 7067

District Court of Appeal of Florida | Filed: Apr 19, 1974 | Docket: 64539198

Published

change in the circumstances of the parties. Fla.Stat. 61.14, F.S.A., (1971); see Carmel v. Carmel, 282

Calhoun v. Calhoun

292 So. 2d 624, 1974 Fla. App. LEXIS 7799

District Court of Appeal of Florida | Filed: Apr 11, 1974 | Docket: 64538196

Published

the facts of this case or the law of the state. F.S. 61.14 (1971), F.S.A. Looking about, the husband in

Pemberton v. Pemberton

292 So. 2d 44, 1974 Fla. App. LEXIS 7704

District Court of Appeal of Florida | Filed: Mar 27, 1974 | Docket: 64537955

Published

PER CURIAM. Affirmed. See Section 61.14, Florida Statutes, F.S.A.; Schulman v. Schulman, Fla.App.3rd

Floyd v. Floyd

281 So. 2d 63, 1973 Fla. App. LEXIS 7610

District Court of Appeal of Florida | Filed: Jul 31, 1973 | Docket: 64533650

Published

successor judge may modify a judgment pursuant to F.S. 61.14, F.S.A., but that he may not make substantial

Landsberg v. Landsberg

280 So. 2d 491, 1973 Fla. App. LEXIS 7852

District Court of Appeal of Florida | Filed: Jul 24, 1973 | Docket: 64533407

Published

modification thereof if properly presented pursuant to § 61.14, Fla.Stat., F.S.A.

Zuccarello v. Zuccarello

280 So. 2d 37, 1973 Fla. App. LEXIS 7802

District Court of Appeal of Florida | Filed: Jul 10, 1973 | Docket: 64533238

Published

support as provided for therein, proceeding under § 61.14(4) Fla.Stat., F.S.A. Attached to the petition was

Mueller v. Mueller

275 So. 2d 585, 1973 Fla. App. LEXIS 7093

District Court of Appeal of Florida | Filed: Apr 10, 1973 | Docket: 64531352

Published

modification of the alimony award in compliance with § 61.14, Fla.Stat., F.S.A., if the circumstances, financial

Serge v. Serge

276 So. 2d 86, 1973 Fla. App. LEXIS 6865

District Court of Appeal of Florida | Filed: Mar 28, 1973 | Docket: 64531616

Published

this type of award is not contemplated by F.S. § 61.14, 1971, F.S.A. which relates to the modification

Fligelman v. Fligelman

272 So. 2d 199, 1973 Fla. App. LEXIS 7378

District Court of Appeal of Florida | Filed: Jan 22, 1973 | Docket: 64529987

Published

parties if such shall occur, as provided for in § 61.14 Fla. Stat., F.S.A. The judgment appealed from is

Marshall v. Marshall

273 So. 2d 107, 1973 Fla. App. LEXIS 7236

District Court of Appeal of Florida | Filed: Jan 17, 1973 | Docket: 64530363

Published

such be applied for and properly allowable under § 61.14, Fla.Stat., F.S.A. Poe v. Poe, Fla.App.1972, 263

Cheves v. Cheves

269 So. 2d 414

District Court of Appeal of Florida | Filed: Nov 15, 1972 | Docket: 64528829

Published

support the children in what amount. Fla.Stat. § 61.14 (1971), F.S.A. provides for modification upon a

Paras v. Paras

262 So. 2d 203, 1972 Fla. App. LEXIS 6701

District Court of Appeal of Florida | Filed: May 19, 1972 | Docket: 64525933

Published

trial court had jurisdiction under Florida Statute § 61.14, F.S.A.1 to modify said agreement by the entry

Groves v. Groves

260 So. 2d 858, 1972 Fla. App. LEXIS 7017

District Court of Appeal of Florida | Filed: Apr 20, 1972 | Docket: 64525458

Published

relief sought by appellant is authorized by F.S. Section 61.14, F.S.A., relating to agreements for payment

Martin v. Martin

261 So. 2d 179, 1972 Fla. App. LEXIS 6840

District Court of Appeal of Florida | Filed: Apr 20, 1972 | Docket: 64525557

Published

agreement until further order of the court. F.S. Section 61.14, F.S.A., relating to modification of alimony

Cooper v. Cooper

260 So. 2d 272, 1972 Fla. App. LEXIS 6962

District Court of Appeal of Florida | Filed: Apr 4, 1972 | Docket: 64525189

Published

to continuous review by the court pursuant to § 61.14, Fla.Stat., F.S.A. We conclude that the chancellor

Walborsky v. Walborsky

258 So. 2d 304, 1972 Fla. App. LEXIS 7217

District Court of Appeal of Florida | Filed: Feb 8, 1972 | Docket: 64524493

Published

final judgment allowing alimony to the wife (Section 61.14, F.S.1967, F.S.A.), there is no statutory authority

Belcher v. Belcher

256 So. 2d 75, 1971 Fla. App. LEXIS 5570

District Court of Appeal of Florida | Filed: Dec 21, 1971 | Docket: 64523685

Published

under changed con- . ditions as provided for in § 61.14, Florida Statutes, F.S.A.” The decision in that

Posner v. Posner

245 So. 2d 139, 1971 Fla. App. LEXIS 6877

District Court of Appeal of Florida | Filed: Mar 2, 1971 | Docket: 64519216

Published

Judgment under the terms and provisions of Section 61.14, Florida Statutes, and the Court will consider

Arthur v. Arthur

243 So. 2d 8, 1971 Fla. App. LEXIS 5339

District Court of Appeal of Florida | Filed: Jan 15, 1971 | Docket: 64518320

Published

from availing herself of the provisions of Section 61.14, Fla.Stats., F.S.A., relative to modification

Libberton v. Libberton

240 So. 2d 336, 1970 Fla. App. LEXIS 5596

District Court of Appeal of Florida | Filed: Oct 28, 1970 | Docket: 64517058

Published

discussed further in this opinion. . Now, Section 61.14, Florida Statutes, F.S.A. . The dower and

Van Boven v. First National Bank in Palm Beach

240 So. 2d 329, 1970 Fla. App. LEXIS 5594

District Court of Appeal of Florida | Filed: Oct 28, 1970 | Docket: 64517057

Published

fact that the court, under authority of F.S. section 61.14, F.S.A., twice entertained appellant’s petitions

Trope v. Trope

238 So. 2d 486, 1970 Fla. App. LEXIS 6009

District Court of Appeal of Florida | Filed: Aug 11, 1970 | Docket: 64516237

Published

judge should find the adjustment proper under § 61.14, Fla.Stat., F.S.A. See, e. g„ Ludacer v. Ludacer

Freeman v. Freeman

234 So. 2d 408, 1970 Fla. App. LEXIS 6524

District Court of Appeal of Florida | Filed: Apr 21, 1970 | Docket: 64514328

Published

discretionary power to amend or alter awards for alimony. § 61.14 Fla.Stat.F.S.A.; Nixon v. Nixon, Fla.App.1967,

McKenna v. McKenna

220 So. 2d 433, 1969 Fla. App. LEXIS 6057

District Court of Appeal of Florida | Filed: Mar 18, 1969 | Docket: 64508996

Published

not subject to modification under § 65.15 (now § 61.14) Fla.Stat, F.S.A. In a separate order the court

Andary v. Andary

220 So. 2d 687, 1969 Fla. App. LEXIS 6100

District Court of Appeal of Florida | Filed: Mar 13, 1969 | Docket: 64509063

Published

Simmons, Fla.App.1966, 192 So.2d 325; F.S.1967, Section 61.14, F.S.A. Normally where a change in circumstances

Coggan v. Coggan

214 So. 2d 368, 1968 Fla. App. LEXIS 4962

District Court of Appeal of Florida | Filed: Sep 27, 1968 | Docket: 64506778

Published

has a broad discretion under Florida Statutes § 61.14 (1967), F.S.A. and has not been shown to have abused

Hamilton v. Hamilton

212 So. 2d 881, 1968 Fla. App. LEXIS 5375

District Court of Appeal of Florida | Filed: Jul 16, 1968 | Docket: 64506356

Published

Harrell v. Harrell, Fla.App.1965, 171 So.2d 214; § 61.14, Fla.Stat., F.S.A. (formerly § 65.15). For the