RAJIV RAMAKRISHNAN
v.
ERIKA RAMAKRISHNAN

Fla. 5th DCA | 2022-12-30
No. 22-0769
Florida District Court of Appeal, Fifth District (2022)

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Holding

A trial court properly reserves jurisdiction to award attorney's fees in a final dissolution judgment when the requesting party raised the issue in pleadings and at trial, and a challenge to fee entitlement is not ripe for appellate review when the court has not yet determined the amount.


Headnotes

[1] A trial court properly reserves jurisdiction to determine attorney's fees in a final judgment of dissolution of marriage when the opposing party requests fees in her plea…

[2] A challenge to entitlement to attorney's fees in a dissolution proceeding is not ripe for appellate review when the trial court has determined entitlement but has not yet…

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Key Quotes

“Because the court's order only determined entitlement but did not set the amount of such fees, the issue is not ripe for determination at this time.”

Court citing Cummings v. Cummings regarding ripeness of attorney's fee challenges

Facts & Procedural History

Rajiv Ramakrishnan appealed an amended final judgment of dissolution of marriage that awarded attorney's fees to his former spouse, Erika Ramakrishnan…

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Opinion of the Court

WALLIS, J.

Appellant appeals the amended final judgment of dissolution of marriage ordering, inter alia, that Appellee is entitled to recover attorney's fees. Appellant argues that the trial court did not properly reserve jurisdiction to rule that Appellee was entitled to fees and that in so doing, the court exceeded the relief that the parties requested. We reject Appellant's arguments and affirm. Cf. Harbin v. Harbin, 762 So. 2d 561, 563 (Fla. 5th DCA 2000) (holding trial court erred in failing to reserve jurisdiction to determine attorney’s fees in the final judgment of modification when wife requested attorney’s fees in her pleadings and at the modification trial). Moreover, Appellant's arguments challenging the entitlement to fees is not ripe for appellate review. Therefore, we dismiss this issue for lack of appellate jurisdiction. See Cummings v. Cummings, 868 So. 2d 1285, 1286 (Fla. 5th DCA 2004) ("Because the court's order only determined entitlement but did not set the amount of such fees, the issue is not ripe for determination at this time.").

AFFIRM IN PART; DISMISS IN PART.

LAMBERT, C.J. and EVANDER, J., concur.


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