SYED IMRAN ALI
v.
SABA SHOUKAT
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Bridge-the-gap alimony requires the requesting party to present evidence of legitimate identifiable short-term needs and the specific time period for which such assistance is needed, and the trial court cannot substitute case law precedent for this factual showing.
[1] Bridge-the-gap alimony under Florida Statute section 61.08(6) requires the requesting party to present evidence of legitimate identifiable short-term needs and the specif…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“when seeking bridge-the-gap alimony, a requesting party must identify 'legitimate identifiable short-term needs' with which assistance is needed to smooth the transition 'from being married to being single.'”
The court explained the statutory requirement for bridge-the-gap alimony awards.
Syed Ali and Saba Shoukat's 249-day marriage with no children was dissolved. The trial court awarded Shoukat $2,675.87 per month in bridge-the-gap ali…
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FIFTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
SYED IMRAN ALI, Appellant,
V.
SABA SHOUKAT, Appellee.
Case No. 5D2025-1410 LT Case No. 42-2023-DR-1624
On appeal from the Circuit Court for Marion County. Jennifer Bass, Judge.
John N. Bogdanoff, of The Carlyle Appellate Law Firm, Orlando, for Appellant.
No Appearance for Appellee.
October 16, 2026
SOUD, J.
Appellant Syed Ali appeals the final judgment of dissolution of marriage that ended his 249-day marriage to Appellee Saba Shoukat.1 He challenges the trial court's distribution of property, the provision of bridge-the-gap alimony to his former wife, and the
award to Shoukat of attorney fees. We have jurisdiction. See Art. V, § 4(b)(1), Fla. Const.; Fla. R. App. P. 9.030(b)(1)(A). We reverse the trial court's award of bridge-the-gap alimony. We affirm in all other respects without further comment.
Following trial, the parties' short-term marriage involving no children was dissolved. Pertinent here, in the final judgment, the trial court ordered Ali to pay $2,675.87 per month to Shoukat as bridge-the-gap alimony to assist her with "legitimate identifiable short[-]term needs . . . to bridge the gap to self-support." Recognizing that Shoukat “did not argue or introduce evidence as to a time period necessary to bridge the gap to self-support other than in her request for lump sum alimony as she will have no way to support herself for the next ‘several months,” the trial court turned to case law “[f]or guidance.” Relying at least in part on Murray v. Murray, 374 So. 2d 622 (Fla. 4th DCA 1979), a case involving an approximately seven-month marriage where the Fourth District reduced a four-year alimony award to six months, the trial court awarded Shoukat bridge-the-gap alimony for a period of nine months, roughly the same timeframe as the length of her marriage to Ali.
The trial court's award of bridge-the-gap alimony is reviewed for abuse of discretion. See Saario v. Tiller, 333 So. 3d 315, 320 (Fla. 5th DCA 2022).
"The party seeking . . . alimony has the burden of proving his or her need . . . and the other party's ability to pay . . .” § 61.08(2)(a), Fla. Stat. (2024). If the trial court finds both need and ability to pay exist, it must then consider the factors set forth in section 61.08(2) to decide the type and amount of alimony appropriately awarded. See Saario, 333 So. 3d at 320.
Relevant to this case, section 61.08(6) provides for bridge-thegap alimony “to provide support to a party in making the transition from being married to being single." This type of alimony, which may not be awarded for more than two years, is non-modifiable and is designed to "assist[] a party with legitimate identifiable short-term needs.” Id. (emphasis added).
Here, the trial court determined Shoukat failed to present evidence as to the amount of time she would need bridge-the-gap
alimony to assist with identifiable needs “other than in her request for lump sum alimony as she will have no way to support herself for the next ‘several months.” Faced with this dearth of evidence, the trial judge turned to case law.
But as the text of the alimony statute makes clear, when seeking bridge-the-gap alimony, a requesting party must identify "legitimate identifiable short-term needs” with which assistance is needed to smooth the transition "from being married to being single." Id. Inherent within this statute is the requirement that Shoukat offer proof as to the legitimate identifiable short-term needs she has, including the time such short-term needs will exist for which the bridge-the-gap alimony is needed. This is a factually based inquiry, and the trial court's determination is to be founded upon the evidence before it. See Murray, 374 So. 2d at 624 (reducing rehabilitative alimony award because “there [was no] evidence that she would require four years to regain her ability for self-support").2
Shoukat's testimony that she needs assistance for a few months is insufficient to adequately inform the trial court as to the proper amount of time to provide bridge-the-gap alimony. And while case law in Florida certainly has its place, precedent cannot substitute for that which only admitted evidence can provide. Thus, the trial court's reliance on Murray in providing bridge-thegap alimony here is misplaced.
Accordingly, we REVERSE in part and AFFIRM in part. We reverse the trial court's award of bridge-the-gap alimony and remand with instructions to vacate the award. We affirm in all other respects.
It is so ordered.
BOATWRIGHT and KILBANE, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Murray v. Murray, 374 So. 2d 622 (Fla. 4th DCA 1979)
- Saario v. Tiller, 333 So. 3d 315 (Fla. 5th DCA 2022)