June 2025 Florida Family Law Update – Salazar v. Blanco
Florida’s Third District Court of Appeal recently weighed in on a head-scratcher of a child support issue in Salazar v. Blanco, and the takeaway is clear: you shouldn’t have to pay child support to the other parent for the time when the child is living with you.
Sounds obvious, right? But that’s not how the trial court ruled.
In Salazar, the mother was ordered to pay child support to the father—even during periods when the child was physically in her custody. The appellate court wasn’t having it. They reversed that part of the judgment, pointing out that support should reflect actual time-sharing, and courts must carefully evaluate the best interests of the child under the factors laid out in Section 61.13, Florida Statutes.
What went wrong below? The trial court failed to properly apply those statutory factors when crafting the parenting plan and support order. That’s a big no-no. Parenting decisions aren’t just about splitting time—they must be grounded in a full analysis of the child’s welfare and family circumstances.
Key Takeaways:
- Courts must consider all best interest factors before finalizing timesharing or parenting plans.
- Child support should match actual custody time. A parent shouldn’t be paying support for days when the child is in their care.
- Trial court shortcuts lead to appeals—and reversals.
This case is a great reminder that custody and support decisions aren’t just checkboxes—they require careful, individualized findings. If you’ve been hit with a support order that doesn’t make sense, you might have appellate options.
Want to talk through your case? Reach out—family law is what we do.