At Fell Law Group, we understand that family law cases are deeply personal and often hinge on complex legal nuances. Three recent Florida appellate decisions shed light on key issues such as child support, alimony, and even the intersection of contracts and state sovereignty. Here’s what you need to know.
1. Atl. Coast Conf. v. FSU Bd. of Trs.
Case Overview: This case addressed a contractual dispute between Florida State University (FSU) and the Atlantic Coast Conference (ACC) over membership and media rights. The trial court denied the ACC’s motion for a stay pending resolution of a similar case in North Carolina, citing critical Florida-specific interests.
Key Takeaways:
- Anticipatory Filing: The court determined that the North Carolina action was an anticipatory filing—a legal strategy used to preemptively file in a preferred jurisdiction. This justified denying the stay.
- Florida’s Sovereign Interests: The court emphasized the importance of Florida’s interests, including whether media rights constitute state property, making this a uniquely Florida matter.
- Impact on Family Law: While not a family law case, this decision highlights how courts prioritize state interests in disputes involving Florida entities—a principle that could extend to family law issues like asset division involving state-connected assets. It also highlights the effects of the principles of comity and priority for divorce cases filed in competing states.
2. A.A. v. M.A.
Case Overview: In this dissolution of marriage case, the Second District Court of Appeal reversed a trial court’s decision to impute income to the wife for child support purposes, citing insufficient evidence.
Key Takeaways:
- Outdated Evidence: The trial court relied solely on the husband’s testimony about the wife’s salary from four years prior. Without evidence of her current qualifications or job opportunities, the imputation was invalid.
- Voluntary Unemployment or Underemployment: The court noted that there was no evidence the wife left her prior job voluntarily or was intentionally underemployed.
- Median Income Standard: The appellate court provided guidance for future proceedings: if imputation is necessary, courts may use the median income for full-time workers based on U.S. Census data to establish a rebuttable presumption.
What It Means: This case serves as a reminder that imputing income requires current, reliable evidence. Parties seeking to impute income should present detailed proof of current employment opportunities, qualifications, and local market conditions.
3. Domnin v. Domnina
Case Overview: The Fourth District Court of Appeal reversed a trial court’s decision to award temporary alimony, attorney’s fees, and suit costs, citing a due process violation.
Key Takeaways:
- Due Process Violation: The husband was denied the opportunity to present his case-in-chief after the wife presented her evidence.
- Impact on Temporary Relief: The appellate court’s decision reinforces that even in temporary hearings, all parties must have an equal opportunity to present their case.
- Judicial Efficiency vs. Fairness: While courts aim to resolve temporary relief hearings quickly, fairness and due process cannot be sacrificed in the interest of expediency.
What It Means: This case underscores the importance of procedural fairness, particularly in high-stakes hearings where temporary financial support is at issue. Each side must be provided an opportunity to present their case.
Conclusion
Whether you’re navigating complex child support calculations, seeking temporary alimony, or dealing with intricate contractual disputes, these cases highlight the importance of evidence, fairness, and advocacy in Florida family law.
At Fell Law Group, we’re committed to protecting your rights and guiding you through every step of the legal process.
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