January 2026 gave Florida family lawyers a tidy trio of appellate reminders that can be summed up in one sentence: trial courts still have to follow the rules, even when the outcome feels “fair.”
In Dove, Paniry, and Jackowska, three different DCAs hit pause on dissolution cases for three very different reasons—financial affidavits, fraud claims, and attorney’s fees—but the theme is consistent: details matter, findings matter, and shortcuts don’t survive appeal.
Let’s break it down.
1. Dove v. Freer: If It Has a Dollar Value, It’s Probably Marital
In Dove v. Freer (4th DCA), the trial court managed to miss on several fundamentals at once—an impressive feat.
First, the alimony award. A simple miscalculation in the husband’s financial affidavit snowballed into an incorrect determination of his ability to pay. The Fourth DCA had no patience for “close enough” math: when ability to pay is wrong, alimony has to be revisited.
Next, credit card debt. The wife incurred the debt before the petition was filed, but after the parties separated. The trial court treated it as nonmarital. That didn’t fly. Without a valid separation agreement, the petition date controls, not when the parties emotionally (or physically) checked out of the marriage.
Finally—and most interestingly—the husband’s accrued leave. The trial court excluded it from equitable distribution. The Fourth DCA reversed, holding that accrued leave is a marital asset when:
- it accrues during the marriage, and
- the employee will be paid for unused leave upon termination.
Bottom line: If it accrues, has value, and pays out, it’s an asset—even if it’s sitting in your HR portal instead of a bank account.
2. Paniry v. Paniry: Fraud Allegations Don’t Come With Free Discovery
In Paniry v. Paniry (3d DCA), the issue wasn’t whether fraud existed—but how you’re allowed to look for it.
The former wife sought to vacate an agreed final judgment, alleging the former husband lied about his income during settlement negotiations. The trial court allowed limited financial discovery before deciding whether the allegations were even legally sufficient.
The Third DCA shut that down.
Before discovery happens, the trial court must:
- Determine whether the motion alleges a prima facie case of fraud, and
- Conduct an evidentiary hearing to decide whether the allegedly hidden information could or should have been discovered before the settlement was signed.
Only then does discovery enter the picture.
Translation: You don’t get to go fishing just because you regret the deal. Settlement agreements still mean something, and fraud claims have to clear real procedural hurdles before reopening the books.
3. Jackowska v. Blessitt: You Can’t Just “Feel” a Fee Reduction
In Jackowska v. Blessitt (2d DCA), the trial court awarded the former wife only part of her requested attorney’s fees—but failed to explain why.
That’s a problem.
Under a proper lodestar analysis, a court must make specific findings about:
- the reasonable number of hours expended,
- the reasonable hourly rate, and
- the basis for any reduction.
The trial court also incorrectly placed the entire burden on the wife to justify her fees. The Second DCA reminded everyone that once a prima facie fee claim is made, the opposing party bears the burden of identifying which hours should be cut—and why.
And if the reduction was meant as a sanction for litigation misconduct? Even more findings are required. The court must explain what misconduct occurred and which fees were caused by it.
In short: You can reduce fees—but you have to show your work.
The Big Picture
These cases aren’t groundbreaking—but they are loud reminders:
- Alimony depends on accurate math, not approximations.
- Marital assets include more than just bank accounts.
- Settlement agreements don’t collapse on suspicion alone.
- Attorney’s fees can’t be trimmed by gut instinct.
For trial courts, the message is clear: make findings, follow procedure, and explain the reasoning.
For litigants and lawyers, it’s a roadmap for preserving issues—and spotting reversible error.
And for anyone thinking, “Surely the appellate court won’t care about that little detail…”—January 2026 says otherwise.