MICHAEL DENNIS, FORMER HUSBAND, APPELLANT,
v.
HOLLI POE DENNIS, FORMER WIFE, APPELLEE
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The Florida appellate court reversed and remanded a trial court's modification of alimony, holding that the trial court failed to adequately explain its determination of the former wife's need for the modified alimony award. The court found that without clear factual findings regarding the wife's present need level, it could not review the reasonableness of the award.
The trial court failed to provide adequate explanation for its determination of the former wife's alimony need, requiring reversal and remand. Voluntary expenses for adult children cannot be considered as a basis for determining alimony need because a parent has no legal obligation to support adult children.
[1] A trial court must explain the reasoning behind the amount of modified alimony awarded.
[2] A trial court's failure to explain the basis for the level of an alimony award necessitates reversal and remand.
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Join FLexlaw to unlock all legal intelligence“It is not readily apparent to us how the trial court determined the wife's present need for alimony, nor did the trial court explain the reason for the level of the award.”
Establishes the core holding that trial courts must explain their determination of alimony need and the basis for the award amount.
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Join FLexlaw to unlock all legal intelligenceThe former husband appealed a final order modifying alimony. The trial court found a substantial change in circumstances warranting modification but d…
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Appellant, the former husband, challenges a final order modifying alimony. He raises several issues on appeal, one of which requires reversal and remand. He asserts the trial court, after finding a substantial change in circumstances, failed to explain the reason for the amount of the modified alimony it awarded to the former wife. It is not readily apparent to us how the trial court determined the wife’s present need for alimony, nor did the trial court explain the reason for the level of the award.* We, therefore, must reverse and remand for the trial court to explain its determination of the former wife’s level of need. See Anderson v. Durham, 162 So.3d 65, 67 (Fla. 1st DCA 2014) (reversing and remanding for more factual findings where a trial court denied a former husband’s motion to modify alimony despite finding his intent to retire was reasonable, because the court “provided no explanation for this decision, and we will not speculate as to the reason”); DePoorter v. DePoorter, 509 So.2d 1141, 1146 (Fla. 1st DCA 1987) (reversing an order reducing permanent alimony because the appel*657late court was “unable to determine what factors were relied upon by the trial court in making the alimony reduction determination”).
BILBREY and WINOKUR, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Grable v. Grable (Fla. 1st DCA 2026)…he obligation of support. § 61.1255, Fla. Stat. (2023). Thus, the needs of an adult, independent child are not provided by Chapter 61 obligations. Florida courts—including this Court—have routinely concluded the same. *See, e.g., Dennis v. Dennis*, 184 So. 3d 656, 656 n.* (Fla. 1st DCA 2016) (concluding that the former wife’s support of the parties’ adult children is an improper consideration in determining a need for alimony); *Schwab*, 864 So. 2d at 84 (concluding that the expenses of the parties’ adult ch…
Authorities Cited
- DePOORTER v. Win Edward DePOORTER, 509 So. 2d 1141 (Fla. 1st DCA 1987)
- Wolfe v. Wolfe, 953 So. 2d 632 (Fla. 4th DCA 2007)
- Anderson v. Durham, 162 So. 3d 65 (Fla. 1st DCA 2014)