Florida Statutes
Fla. Stat. § 61.14 (2025)
Enforcement and modification of support, maintenance, or alimony agreements or orders.
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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.
Notes of Decisions
Cited in 519
cases (26 in the last 5 years), 1962–2026 · leading case: Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008).
Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008). “This paragraph recognizes only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.”
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
King v. King, 82 So. 3d 1124 (Fla. 2d DCA 2012). “Reading subsection (l)(b) of the statute in pari materia with subsection (l)(a) compels the conclusion that a supportive relationship does not authorize a reduction or termination of alimony unless the relationship began after the divorce and after the alimony award.”
Dep't of Revenue v. Jackson, 846 So. 2d 486 (Fla. 2003). “Section 61.14, Florida Statutes (2001), contemplates that either party in the original action may seek modification of an order requiring the payment of support "as equity requires.”
Pompey v. Cochran, 685 So. 2d 1007 (Fla. 4th DCA 1997). “[7] They reason that, because the child support judgment was entered in 1986 before this statute was adopted in 1992, it may not be applied in this case.”
State Ex Rel. Pittman v. Stanjeski, 562 So. 2d 673 (Fla. 1990). “We have jurisdiction. [1] We agree that the statute as interpreted by the district courts would be unconstitutional.”
Posner v. Posner, 233 So. 2d 381 (Fla. 1970). “Section 61.14, Florida Statutes, F.S.A. (Ch.”
Pimm v. Pimm, 601 So. 2d 534 (Fla. 1992). “1954); § 61.14(1), Fla. Stat. (Supp. 1988). Second, the change was not contemplated at the time of final judgment of dissolution.”
Bedell v. Bedell, 583 So. 2d 1005 (Fla. 1991). “However, a careful analysis of the wording of section 61.14 leads us to believe that the solution lies between the two positions.”
Jarrard v. Jarrard, 157 So. 3d 332 (Fla. 2d DCA 2015). “Jarrard in this case, seek modification of alimony under section 61.14, Florida Statutes (2012). A mixed standard of review is actually performed by an appellate court as a sequence of two or more distinct reviews.”
Muss v. Muss, 390 So. 2d 415 (Fla. 3d DCA 1980). “*416 Appellant Carole Muss filed suit in the Dade County Circuit Court in 1978 to have the New York divorce decree established and recognized as a judgment in the State of Florida, and to increase her alimony payments pursuant to Section 61.14, Florida Statutes (1979). The trial…”
Regan v. Regan, 217 So. 3d 91 (Fla. 4th DCA 2017). “Section 61.14, Florida Statutes (2015), provides for the ability to modify alimony and support which was previously set in a final judgment or in an agreed settlement: When the parties enter into an agreement for payments for, or instead of, support, maintenance, or alimony, .”
— 61.14(1) — 89 cases
Pimm v. Pimm, 601 So. 2d 534 (Fla. 1992). “1954); § 61.14(1), Fla. Stat. (Supp. 1988). Second, the change was not contemplated at the time of final judgment of dissolution.”
Bedell v. Bedell, 583 So. 2d 1005 (Fla. 1991). “However, a careful analysis of the wording of section 61.14 leads us to believe that the solution lies between the two positions.”
King v. King, 82 So. 3d 1124 (Fla. 2d DCA 2012). “Reading subsection (l)(b) of the statute in pari materia with subsection (l)(a) compels the conclusion that a supportive relationship does not authorize a reduction or termination of alimony unless the relationship began after the divorce and after the alimony award.”
Bedell v. Bedell, 561 So. 2d 1179 (Fla. 3d DCA 1989).
Overbey v. Overbey, 698 So. 2d 811 (Fla. 1997).
— 61.14(1)(a) — 43 cases
Dep't of Revenue v. Jackson, 846 So. 2d 486 (Fla. 2003). “Section 61.14, Florida Statutes (2001), contemplates that either party in the original action may seek modification of an order requiring the payment of support "as equity requires.”
Robert W. Bauchman v. Berta Bauchman, 253 So. 3d 1143 (Fla. 4th DCA 2018).
Woolf v. Woolf, 901 So. 2d 905 (Fla. 4th DCA 2005).
Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008). “This paragraph recognizes only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.”
Acker v. Acker, 904 So. 2d 384 (Fla. 2005).
— 61.14(1)(b) — 12 cases
Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008). “This paragraph recognizes only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.”
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
Bruce v. Bruce - corrected 2/5/18, 243 So. 3d 461 (Fla. 5th DCA 2018).
Zeballos v. Zeballos, 951 So. 2d 972 (Fla. 4th DCA 2007).
Atkinson v. Atkinson, 157 So. 3d 473 (Fla. 2d DCA 2015).
— 61.14(1)(b)(1) — 2 cases
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
Atkinson v. Atkinson, 157 So. 3d 473 (Fla. 2d DCA 2015).
— 61.14(1)(b)(2) — 2 cases
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
Dena Spector v. Seth Spector (Fla. 3d DCA 2023).
— 61.14(1)(b)(2)(a) — 1 case
Dena Spector v. Seth Spector (Fla. 3d DCA 2023).
— 61.14(1)(b)(2)(d) — 1 case
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
— 61.14(1)(b)(3) — 1 case
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
— 61.14(1)(c) — 1 case
Cole v. Cole, 723 So. 2d 925 (Fla. 3d DCA 1999).
— 61.14(10) — 1 case
State of Florida, Dep't of Revenue, Child Support Prog. v. Jean Fucien (Fla. 3d DCA 2026).
— 61.14(11) — 5 cases
Ghay v. Ghay, 954 So. 2d 1186 (Fla. 2d DCA 2007).
Murphy v. Murphy, 948 So. 2d 864 (Fla. 5th DCA 2007).
Kasm v. Lynnel, 975 So. 2d 560 (Fla. 2d DCA 2008).
Ehiabor v. Ehiabor (Fla. 1st DCA 2026).
Craig D Carter, Sr. v. Lenora J. Carter (Fla. 4th DCA 2020).
— 61.14(11)(a) — 2 cases
Riddle v. Riddle, 214 So. 3d 694 (Fla. 4th DCA 2017).
Joshua S. Winegar v. Gabrielle D. Winegar (Fla. 4th DCA 2026).
— 61.14(2) — 1 case
Burkley v. Burkley, 911 So. 2d 262 (Fla. 5th DCA 2005).
— 61.14(3) — 2 cases
Dept. of Health & Rehab. Servs. v. Porbansky, 569 So. 2d 815 (Fla. 5th DCA 1990).
Prout v. Prout, 415 So. 2d 905 (Fla. 3d DCA 1982).
— 61.14(4) — 1 case
Zuccarello v. Zuccarello, 280 So. 2d 37 (Fla. 3d DCA 1973).
— 61.14(5) — 9 cases
State Ex Rel. Pittman v. Stanjeski, 562 So. 2d 673 (Fla. 1990). “We have jurisdiction. [1] We agree that the statute as interpreted by the district courts would be unconstitutional.”
Pompey v. Cochran, 685 So. 2d 1007 (Fla. 4th DCA 1997). “[7] They reason that, because the child support judgment was entered in 1986 before this statute was adopted in 1992, it may not be applied in this case.”
State Ex Rel. Pittman v. Stanjeski, 541 So. 2d 1214 (Fla. 2d DCA 1989).
Jones v. Jones, 671 So. 2d 852 (Fla. 5th DCA 1996).
Randall v. Griffin, 204 So. 3d 965 (Fla. 5th DCA 2016).
— 61.14(5)(a) — 21 cases
Pompey v. Cochran, 685 So. 2d 1007 (Fla. 4th DCA 1997). “[7] They reason that, because the child support judgment was entered in 1986 before this statute was adopted in 1992, it may not be applied in this case.”
Elliott v. Bradshaw, 59 So. 3d 1182 (Fla. 4th DCA 2011).
State Ex Rel. Pittman v. Stanjeski, 562 So. 2d 673 (Fla. 1990). “We have jurisdiction. [1] We agree that the statute as interpreted by the district courts would be unconstitutional.”
Mallardi v. Jenne, 721 So. 2d 380 (Fla. 4th DCA 1998).
Amendments to the Florida Fam. Law Rules, 713 So. 2d 1 (Fla. 1998).
— 61.14(5)(b) — 2 cases
Randall v. Griffin, 204 So. 3d 965 (Fla. 5th DCA 2016).
State Ex Rel. Pittman v. Stanjeski, 541 So. 2d 1214 (Fla. 2d DCA 1989).
— 61.14(5)(c) — 1 case
Mederos v. Selph (L.T.), Inc., 625 So. 2d 894 (Fla. 5th DCA 1993).
— 61.14(5)(d) — 2 cases
State Ex Rel. Pittman v. Stanjeski, 562 So. 2d 673 (Fla. 1990). “We have jurisdiction. [1] We agree that the statute as interpreted by the district courts would be unconstitutional.”
Attorney Gen. of Florida ex rel. State v. D'Agosto, 541 So. 2d 167 (Fla. 4th DCA 1989).
— 61.14(6) — 1 case
Vitt v. Rodriguez, 960 So. 2d 47 (Fla. 5th DCA 2007).
— 61.14(6)(a) — 3 cases
Pyne v. Black, 650 So. 2d 1073 (Fla. 5th DCA 1995).
Pyne v. Black, 650 So. 2d 1073 (Fla. 5th DCA 1995).
Shaarbay v. Alvarez, 255 So. 3d 487 (Fla. 3d DCA 2018).
— 61.14(6)(a)(1) — 1 case
Kranz v. Kranz, 661 So. 2d 876 (Fla. 3d DCA 1995).
— 61.14(6)(a)(3) — 1 case
Dep't of Revenue v. Jackson, 846 So. 2d 486 (Fla. 2003). “Section 61.14, Florida Statutes (2001), contemplates that either party in the original action may seek modification of an order requiring the payment of support "as equity requires.”
— 61.14(6)(a)(l) — 1 case
Bieda v. Bieda, 42 So. 3d 859 (Fla. 3d DCA 2010).
— 61.14(6)(b)(1) — 1 case
Dep't of Revenue v. Jackson, 846 So. 2d 486 (Fla. 2003). “Section 61.14, Florida Statutes (2001), contemplates that either party in the original action may seek modification of an order requiring the payment of support "as equity requires.”
— 61.14(6)(d) — 1 case
Raynessa T. Parris v. Azariah B. Israel (Fla. 2d DCA 2023).
— 61.14(7) — 12 cases
Knight v. Knight, 702 So. 2d 242 (Fla. 4th DCA 1997).
Garvey v. Garvey, 138 So. 3d 1115 (Fla. 4th DCA 2014).
Regan v. Regan, 217 So. 3d 91 (Fla. 4th DCA 2017). “Section 61.14, Florida Statutes (2015), provides for the ability to modify alimony and support which was previously set in a final judgment or in an agreed settlement: When the parties enter into an agreement for payments for, or instead of, support, maintenance, or alimony, .”
Daniel Inman v. Catherine Inman, 260 So. 3d 555 (Fla. 2d DCA 2018).
Matthews v. Matthews, 677 So. 2d 323 (Fla. 1st DCA 1996).
— 61.14(9) — 2 cases
Dep't of Revenue Ex Rel. Tisdale v. Jackson, 217 So. 3d 192 (Fla. 5th DCA 2017).
Kirby Marbrando Grant, Jr. v. State of Florida, Dep't of Revenue, Child Support Prog. & Brittney Nicole Johnson (Fla. 1st DCA 2025).
— 61.14(X)(b) — 1 case
Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008). “This paragraph recognizes only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.”
— 61.14(a) — 3 cases
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
Ozuna v. Sheard, 109 So. 3d 1176 (Fla. 3d DCA 2013).
Dep't of Revenue v. Sean Michael Wolf & Christina Lian Guilliams, 164 So. 3d 101 (Fla. 1st DCA 2015).
— 61.14(b) — 4 cases
Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008). “This paragraph recognizes only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.”
French v. French, 4 So. 3d 5 (Fla. 4th DCA 2009).
Buxton v. Buxton, 963 So. 2d 950 (Fla. 2d DCA 2007). “Nothing in any statute purports to eliminate these "relevant economic factors" when modifying alimony under section 61.14. Indeed, section 61.08(2) specifies that it applies whenever the court is "determining a proper award of alimony" under the statute.”
White v. White, 3 So. 3d 400 (Fla. 2d DCA 2009).
— 61.14(b)(1) — 1 case
White v. White, 3 So. 3d 400 (Fla. 2d DCA 2009).
— 61.14(l)(a) — 26 cases
Regan v. Regan, 217 So. 3d 91 (Fla. 4th DCA 2017). “Section 61.14, Florida Statutes (2015), provides for the ability to modify alimony and support which was previously set in a final judgment or in an agreed settlement: When the parties enter into an agreement for payments for, or instead of, support, maintenance, or alimony, .”
Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008). “This paragraph recognizes only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.”
Jarrard v. Jarrard, 157 So. 3d 332 (Fla. 2d DCA 2015). “Jarrard in this case, seek modification of alimony under section 61.14, Florida Statutes (2012). A mixed standard of review is actually performed by an appellate court as a sequence of two or more distinct reviews.”
King v. King, 82 So. 3d 1124 (Fla. 2d DCA 2012). “Reading subsection (l)(b) of the statute in pari materia with subsection (l)(a) compels the conclusion that a supportive relationship does not authorize a reduction or termination of alimony unless the relationship began after the divorce and after the alimony award.”
Schmachtenberg v. Schmachtenberg, 34 So. 3d 28 (Fla. 3d DCA 2010).
— 61.14(l)(b) — 16 cases
Linstroth v. Dorgan, 2 So. 3d 305 (Fla. 4th DCA 2008). “This paragraph recognizes only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.”
King v. King, 82 So. 3d 1124 (Fla. 2d DCA 2012). “Reading subsection (l)(b) of the statute in pari materia with subsection (l)(a) compels the conclusion that a supportive relationship does not authorize a reduction or termination of alimony unless the relationship began after the divorce and after the alimony award.”
French v. French, 4 So. 3d 5 (Fla. 4th DCA 2009).
Jarrard v. Jarrard, 157 So. 3d 332 (Fla. 2d DCA 2015). “Jarrard in this case, seek modification of alimony under section 61.14, Florida Statutes (2012). A mixed standard of review is actually performed by an appellate court as a sequence of two or more distinct reviews.”
Murphy v. Murphy, 201 So. 3d 18 (Fla. 3d DCA 2013).
— 61.14(l)(b)(2) — 4 cases
King v. King, 82 So. 3d 1124 (Fla. 2d DCA 2012). “Reading subsection (l)(b) of the statute in pari materia with subsection (l)(a) compels the conclusion that a supportive relationship does not authorize a reduction or termination of alimony unless the relationship began after the divorce and after the alimony award.”
Baumann v. Baumann, 22 So. 3d 719 (Fla. 2d DCA 2009).
Overton v. Overton, 34 So. 3d 759 (Fla. 1st DCA 2010).
Tarkow v. Tarkow, 128 So. 3d 82 (Fla. 2d DCA 2013).
— 61.14(l)(b)(3) — 1 case
Morrell v. Morrell, 113 So. 3d 857 (Fla. 2d DCA 2012).
— 61.14(l)(b)(l) — 3 cases
Overton v. Overton, 34 So. 3d 759 (Fla. 1st DCA 2010).
King v. King, 82 So. 3d 1124 (Fla. 2d DCA 2012). “Reading subsection (l)(b) of the statute in pari materia with subsection (l)(a) compels the conclusion that a supportive relationship does not authorize a reduction or termination of alimony unless the relationship began after the divorce and after the alimony award.”
Morrell v. Morrell, 113 So. 3d 857 (Fla. 2d DCA 2012).
— 61.14(ll)(a) — 2 cases
Haritos v. Haritos, 193 So. 3d 1050 (Fla. 2d DCA 2016).
Schecter v. Schecter, 109 So. 3d 833 (Fla. 3d DCA 2013).
— 61.14(ll)(b) — 1 case
Hoover v. Florida Dep't of Revenue ex rel. Mitchell, 114 So. 3d 494 (Fla. 1st DCA 2013).
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