The 2023 Florida Statutes (including Special Session C)
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. . . See § 61.14(1)(a), Fla. Stat. (2018). . . . 157 So. 3d 332, 337 (Fla. 2d DCA 2015) (mixed standard of review for modifications of alimony under § 61.14 . . . The pertinent portions of section 61.14(1), Florida Statutes, have not been amended since 2003. . . . (listing factors to be considered in evaluating need and ability to pay alimony); § 61.14(1)(a), Fla. . . .
. . . . §§ 61.14, 61.30(14), Fla. Stat.; Fla. Fam. L.R.P. 12.285(k). . . .
. . . the Former Wife cohabited with the live-in paramour, making her ineligible for alimony under section 61.14 . . . Did Not Err in Failing to Award Alimony The Former Wife argues the court erred in applying section 61.14 . . . But before addressing section 61.14, the court specifically found the Former Wife did not have the need . . . The Former Wife argues section 61.14 applies only to amend a judgment. . . . As a result, she argues, section 61.14 could not be applied to amend the marital settlement agreement . . .
. . . on "alleged dumping at 254.25 percent, the two individually investigated parties received rates of 61.14 . . . is the same rate received by parties who did not request administrative review and is lower than the 61.14% . . .
. . . First, section 61.14(1)(a), Florida Statutes (2017), provides in pertinent part: When the parties enter . . . , with due regard to the ... changed financial abilities of the parties" in accordance with section 61.14 . . .
. . . substantial change in circumstances requiring an increase in the father's child support obligation, see § 61.14 . . .
. . . He alternatively sought modification under section 61.14(1)(a), Florida Statutes (2016), based on the . . . imposed a heavier burden than that required by law in denying the request for modification under section 61.14 . . . The Former Husband alternatively sought modification under section 61.14(1)(a), based on the changed . . . the same regardless of whether the award was established by court order or settlement agreement. § 61.14 . . . However, as our sister courts have recognized, we are bound by the language of section 61.14(7). . . .
. . . been a substantial change in circumstances-a prerequisite to any change in support obligations, see § 61.14 . . .
. . . . § 61.14(1)(a), Fla. Stat. (2016). In Thyrre v. . . .
. . . ." § 61.14(1)(a), Fla. Stat. (2017). . . .
. . . See, e.g., §§ 61.13, 61.14, Fla. . . .
. . . See § 61.14(1)(a), Fla. Stat. (2016) ; see also Wolfe v. . . . 61.08(2) factors in determining alimony must be considered in modification proceedings under section 61.14 . . .
. . . Concerning modifications of support, maintenance, and alimony agreements or orders, section 61.14(1)( . . . The MSA made alimony "modifiable in accordance with Florida Statutes" and section 61.14(1)(a) makes alimony . . .
. . . The trial court determined that it lacked subject matter jurisdiction, reasoning that section 61.14, . . . Section 61.14(1)(a) specifically grants circuit courts the authority to hear modification of alimony . . . cases in the circuit in which the agreement was executed. § 61.14(1)(a), Fla. . . . See § 61.14(1)(a), Fla. Stat. (2003) ; Paulk v. Paulk , 504 So.2d 790, 790 (Fla. 1st DCA 1987). . . . Although these are older cases, the relevant statutory language of section 61.14 remains the same. . . .
. . . Florida's supportive relationship statute, section 61.14(1)(b), Florida Statutes (2015 ), is not applicable . . . However, the factors found in section 61.14(1)(b) provide the trial court with a useful framework to . . .
. . . Supportive Relationship—a relationship, defined in section 61.14(l)(b)l, Florida Statutes, existing between . . .
. . . . § 61.14(l)(a), Fla. Stat. (2015). . . . agreement and the proof required to modify an award established by court order shall be the same.” § 61.14 . . . “Section 61.14 ;.. extends jurisdiction to the trial courts to ’make orders as equity requires’ to modify . . . Mouton, 590 So.2d 40, 41 (Fla. 2d DCA 1991) (quoting § 61.14(1), Florida- Statutes (1989)). . . .
. . . See § 61.14, Fla. Stat. (2017). . . .
. . . statutory right to seek modification, we reverse and remand for further proceedings pursuant to section 61.14 . . . Section 61.14(l)(a) allows a party to apply to a circuit court for an order modifying an alimony obligation . . . trial court to reinstate the Former Husband’s petition and for further proceedings pursuant to section 61.14 . . .
. . . , that the Trustee is awarded commissions in the amount of $9,572.20 and expenses in the amount of $61.14 . . .
. . . Stat. (2015); see also § 61.14(9), Fla. . . .
. . . Section 61.14, Florida Statutes (2015), provides for the ability to modify alimony and support which . . . confirming the amount of separate support, maintenance, or alimony provided for in the agreement or order. § 61.14 . . . agreement and the proof required to modify an award established by court order shall be the same. § 61.14 . . . alimony “as equity requires, with due regard to the changed circumstances or financial ability[,]” § 61.14 . . . Given the broad discretion which section 61.14(l)(a) gives the trial judge to make a reduction, “as equity . . .
. . . (providing the standard for modification of a parenting plan in a final judgment of dissolution); § 61.14 . . .
. . . petition alleged dumping at 254.25 percent, the two individually investigated parties received rates of 61.14 . . .
. . . Pursuant to EN 61.14, heading 6114 covers: (1) Aprons, boiler suits (coveralls), smocks and other protective . . . When the nature of the article is unclear, EN 61.14 describes the article by reference to an identifiable . . .
. . . 2), and 61 percent black, (Doc. 296-1 at 3); the McClammy Plan had a black population percentage of 61.14 . . .
. . . and that Former Wife could seek relief by filing a petition for modification pursuant • to section 61.14 . . .
. . . See § 61.14(5)(b), Fla. Stat. (2015). . . . Furthermore, the trial court shall comply with Florida Family Law Rule of Procedure 12.615(d) and section 61.14 . . .
. . . may be modified or terminated based upon a substantial change in circumstances in accordance with s.61.14 . . . substantial change in circumstances or upon the existence of a supportive relationship in accordance with s.61.14 . . .
. . . orders terminate when the child turns 18 “unless the court finds ... that [section] 743.07(2) applies”), 61.14 . . .
. . . Section 61.14(l)(a), Florida Statutes (2013), allows for the modification of a marital settlement agreement . . .
. . . .; see also § 61.14(l)(a), Fla. Stat. . . .
. . . . § 61.14(l)(b), Fla. Stat. (2015). . . . Section 61.14, Florida Statutes (2015), sets out circumstances that a trial court shall weigh in making . . . The extent to which the obligee or the other person has supported the other, in whole or, in part. § 61.14 . . .
. . . jurisdiction to rule on the issues of child support and alimony is set forth in sections 61.13 and 61.14 . . . Overbey, 698 So.2d 811, 813 (Fla.1997) (“Generally, under [sections 61.13 and 61.14], a fundamental prerequisite . . . vacate, or set aside a temporary support order before or upon entering a final order in a proceeding.” § 61.14 . . .
. . . the judgment is paid, except for judgments1 entered by the clerk of the court pursuant to ss. 55.141, 61.14 . . .
. . . father when father’s petition for modification of child support was filed five months later); see also § 61.14 . . .
. . . . - See § 61.14(1)(b), Fla, Stat. (2015). . . .
. . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . .
. . . See, e.g., § 61.14, Fla. Stat. . . .
. . . substitute language referring to the “existence of a supportive relationship” in accordance with section 61.14 . . .
. . . , whether done by a circuit judge or an administrative court, are governed by sections 409.2563 and 61.14 . . . At this juncture, we run squarely into potentially conflicting language in sections 409.2563 and 61.14 . . . The Department points to section 61.14, entitled “Enforcement and modification of support, maintenance . . . But for the word “prospectively” in subsection 409.2563(12), the two statutory frameworks — 61.14(l)( . . . In cases like the present one, subsection 61.14(l)(a) allows modifications to potentially extend back . . .
. . . the judgment is paid, except for judgments entered by the clerk of the court pursuant to ss. 55.141, 61.14 . . .
. . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . .
. . . [P]ursuant to section 61.14(l)(a), a parent seeking modification of child support payments because he . . .
. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . . The first paragraph of the pleading cites section 61.14(1), Florida Statutes, which discusses modification . . .
. . . findings that the Former Wife was not engaged in a “supportive relationship” within the meaning of section 61.14 . . . In addressing this question, we need not consider the application of section 61.14(1)(b). . . . The legislature enacted section 61.14(1)(b) in 2005 to “provide an alternate method to a court to reduce . . . In accordance with section 61.14(1)(b)(1), “[t]he court may reduce or terminate an award of alimony upon . . . See also Buxton, 963 So.2d at 951-52 (discussing section 61.14(1)(b) and the Senate Staff Analysis of . . .
. . . court’s conclusion that the former wife was not engaged in a “supportive relationship” under section 61.14 . . . Jarrard in this case, seek modification of alimony under section 61.14, Florida Statutes (2012). . . . If the trial court decides to modify alimony, section 61.14(l)(a) authorizes a modification retroactive . . . In this case, section 61.14(l)(a) would appear to give the trial court discretion to adjust alimony to . . .
. . . Galligher, 527 So.2d 858, 860 (Fla. 1st DCA 1988); § 61.14(1), Fla. Stat. (2009). . . .
. . . Tobin, 201 So.2d 799, 800-01 (Fla. 3d DCA 1967)); see also § 61.14, Fla. . . . Since then, section 61.14, Florida Statutes has stated, “When modification of an existing order of support . . . agreement and the proof required to modify an award established by court order shall be the same.” § 61.14 . . .
. . . Explanatory Note 61.14. . . .
. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . .
. . . Under section 61.14(l)(b)l., Florida Statutes (2012), a court may reduce or terminate alimony if “a supportive . . . As we have explained: [Sjection 61.14(l)(b) requires the court to determine if an alimony obligee has . . . Section 61.14(l)(b) is actually a codification of prior case law which held that, in post dissolution . . .
. . . See § 61.14(5)(a), Fla. . . .
. . . See § 61.14(1)(a), Fla. Stat. (2013). . . .
. . . Section 61.14(1)(a), Florida Statutes, governs modification of support and provides the following in . . . requires, with due regard to the changed circumstances or the financial abilities of the parties .... § 61.14 . . . agreement and the proof required to modify an award established by court order shall be the same.” § 61.14 . . . Pratt, 645 So.2d 510, 511 n. 1 (Fla. 3d DCA 1994) (recognizing that section 61.14, Florida Statutes, . . . burden of proof to apply to modification of alimony set by agreement and alimony set by the court); § 61.14 . . .
. . . settling alimony rights is subject to increase or decrease under changed conditions as provided in section 61.14 . . .
. . . A review of a trial court’s decision under section 61.14(l)(b), Florida Statutes (2012), is a mixed question . . .
. . . Mark Llerena (“Llerena”) were involved in a “supportive relationship” within the meaning of section 61.14 . . . or the financial ability of either party changes ....”§ 61.14(l)(a); see also King, 82 So.3d at 1131 . . . To obtain a modification under section 61.14(l)(a), the trial court must make a determination that: ( . . . Section 61.14(l)(b) provides, in relevant part, as follows: 1. . . . See §. 61.14(l)(b)2.d., e.,.k. . . .
. . . Supportive Relationship — a relationship, defined in section 61.14(l)(b)l, Florida Statutes, existing . . . substantial change in circumstances, or the existence of a supportive relationship in accordance with section 61.14 . . . substantial change in circumstances or the existence of a supportive relationship in accordance with section 61.14 . . .
. . . also alleged that the Former Wife was in a “supportive relationship” within the meaning of section 61.14 . . . In addition, based on the evidence and a review of the factors outlined in section 61.14(l)(b)(2), the . . .
. . . . § 61.14(ll)(b). . . .
. . . EN 61.14. The Bra Top is not described by the terms of any heading in the group 6101-6113, HTSUS. . . . See' EN 62.11 (“[U]nlike heading 61.14 this heading also covers tailored waistcoats separately presented . . .
. . . EN 61.14. . . .
. . . Mann filed his petition for modification of a paternity support order, pursuant to section 61.14, Florida . . . Yeatts’ counsel specifically argued that section 61.14 did not apply to the case because it was a paternity . . . proper in Putnam County because a modification of a paternity support order is maintained under section 61.14 . . .
. . . Explanatory Notes to Heading 61.14 (2012). . . . football and therefore classifiable under subheading 6114.30.30); see also Explanatory Notes to Heading 61.14 . . .
. . . or modify an obligation to pay alimony by invoking Florida’s supportive relationship statute section 61.14 . . . Smith, was in a supportive relationship as defined under Florida’s supportive relationship statute. § 61.14 . . . Florida’s supportive relationship statute section 61.14(l)(b), “is actually a codification of prior case . . . Florida’s statute section 61.14 provides in pertinent part: The court may reduce or terminate an award . . . supportive relationship has existed between the obligee and a person with whom the obligee resides. 61.14 . . .
. . . Section 61.14(a), Florida Statutes (2012), specifically permits a child support modification action to . . . Section 61.14(l)(a), provides, in pertinent part: When the parties enter into an agreement, for payments . . .
. . . substantial change in circumstances or upon the existence of a supportive relationship in accordance ■with s. 61.14 . . .
. . . Section 61.14(ll)(a), of the Florida Statutes provides that “[a] court may, upon good cause shown, and . . .
. . . Under section 61.14(1)(a), Florida Statutes (2010), a party who is required to pay child support may . . . Section 61.14(1)(a) provides only these bases for requesting modification, and, as to change in circumstances . . . After confirming the permissible grounds in section 61.14(1)(a) for requesting modification, the court . . . Reading sections 61.13(1)(a) and 61.14(1)(a) in pari materia, the supreme court concluded that “the father . . .
. . . Under section 61.14, Florida Statutes (2011), statutory modification is available to a former spouse . . . there was no basis for the former wife’s claim and remand for further proceedings pursuant to section 61.14 . . .
. . . . § 61.14(1), Fla. Stat. (2010); Pimm v. Pimm, 601 So.2d 534, 536 (Fla.1992). . . . requires, giving due regard to the changed circumstances or the financial ability of the parties.” § 61.14 . . .
. . . all applicable section 61.08(2) factors must be considered in modification proceedings under section 61.14 . . .
. . . cohabited with a third party, with whom she was in a supportive relationship within the meaning of section 61.14 . . . Section 61.14(l)(b) recognizes the economic support that occurs when independent individuals cho[o]se . . . previously expressly held that, when deciding whether to reduce or terminate alimony under section 61.14 . . . the economic factors enumerated in section 61.08(2) apply to modification proceedings under section 61.14 . . . supportive relationship has existed between the obligee and a person with whom the obligee resides.” § 61.14 . . .
. . . See § 61.14(l)(b)(l), Fla. . . . remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances.” § 61.14 . . .
. . . Subsection (b) of section 61.14(1) is sometimes referred to as “the cohabitation statute.” . . . The legislature added subsection (b) to section 61.14(1) in 2005. . . . First, the circuit court must “elicit the nature and extent of the relationship in question.” § 61.14 . . . When the legislature enacted subsection (b) in 2005, it added the new law to section 61.14(1). . . . Hosford, 362 So.2d 973 (Fla. 1st DCA 1978) and § 61.14, Fla. Stat. (2004)). . . .
. . . See § 61.14(l)(a), Fla. Stat. (2010); see also Wiele v. . . . Section 61.14(l)(a), which allows a court to “modify an order of support, maintenance or alimony,” empowers . . .
. . . .; see also, § 61.14, Fla. Stat. (equitable result desired in modification proceedings). . . .
. . . See § 61.14(5)(a), Fla. . . .
. . . Section 61.14(l)(a), Florida Statutes (2009), gives the trial court broad authority to enter orders enforcing . . .
. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . .
. . . Pursuant to section 61.14(5)(a), Florida Statutes (2010), husband is presumed to have a continuing ability . . . Bieluch, 814 So.2d 448 (Fla. 4th DCA 2001) (recognizing that section 61.14(5)(a) controls the burden . . . conclusory finding that husband had the present ability to pay and noting that the presumption of section 61.14 . . .
. . . . § 61.14(l)(a), Fla. Stat. (2006); Bedell v. Bedell, 583 So.2d 1005, 1007 (Fla.1991). . . . Rather, based on the language contained in section 61.14(l)(a) and the supreme court’s analysis in Bedell . . . here and in Eisemann, a party will be precluded from seeking modification, notwithstanding section 61.14 . . . In summary, the situation here reflects changed circumstances as contemplated by section 61.14(l)(a), . . . Modification Pursuant to section 61.14(l)(a), Florida Statutes (2006), “[when] the parties enter into . . .
. . . See § 61.14(l)(a), Fla. . . .
. . . Kusick, 944 So.2d 1081, 1082 (Fla. 2d DCA 2006), and citing section 61.14, Florida Statutes). . . .
. . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . .
. . . review, and provides no basis upon which modification might be sought in the future pursuant to section 61.14 . . .
. . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . .
. . . The trial court, after using the criteria set forth in section 61.14(l)(b)2., Florida Statutes (2007) . . .
. . . Kusick, 944 So.2d 1081, 1082 (Fla. 2d DCA 2006); see also § 61.14(l)(a), Fla. . . .
. . . Although section 61.14(6)(a)(l), Florida Statutes (2009), provides for a summary procedure in which delinquent . . .
. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . .
. . . Jenne, 721 So.2d 380, 383 (Fla. 4th DCA 1998) (discussing amendment to section 61.14, Florida Statutes . . .
. . . See § 61.14(l)(b)(l)-(2), Florida Statutes (2007); French v. . . . Section 61.14(l)(b)(l) provides that, upon specific findings that a supportive relationship exists between . . . Section 61.14(l)(b)(2) delineates factors that the trial court “shall give consideration to” when determining . . . Section 61.14(l)(b) recognizes the economic support that occurs when independent individuals chose to . . . the instant case, the trial court did not make any findings regarding the factors outlined in section 61.14 . . .
. . . Analysis Section 61.14, Florida Statutes (2007), provides in relevant part as follows: (l)(a) When the . . . See § 61.14(l)(a); Chambliss v. Chambliss, 921 So.2d 822, 824 (Fla. 2d DCA 2006). Affirmed. . . .
. . . See § 61.14(1); Hudson-McCann v. McCann, 8 So.3d 1228, 1230 (Fla. 5th DCA 2009). . . .
. . . Here, the trial court, invested with authority by section 61.14(l)(a), Florida Statutes, made a modification . . .