The 2023 Florida Statutes (including Special Session C)

Title VI
CIVIL PRACTICE AND PROCEDURE

Chapter 61
DISSOLUTION OF MARRIAGE; SUPPORT; TIME-SHARING

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F.S. 61.14

61.14 Enforcement and modification of support, maintenance, or alimony agreements or orders.—

(1)(a) When the parties enter into an agreement for payments for, or instead of, support, maintenance, or alimony, whether in connection with a proceeding for dissolution or separate maintenance or with any voluntary property settlement, or when a party is required by court order to make any payments, and the circumstances or the financial ability of either party changes or the child who is a beneficiary of an agreement or court order as described herein reaches majority after the execution of the agreement or the rendition of the order, either party may apply to the circuit court of the circuit in which the parties, or either of them, resided at the date of the execution of the agreement or reside at the date of the application, or in which the agreement was executed or in which the order was rendered, for an order decreasing or increasing the amount of support, maintenance, or alimony, and the court has jurisdiction to make orders as equity requires, with due regard to the changed circumstances or the financial ability of the parties or the child, decreasing, increasing, or confirming the amount of separate support, maintenance, or alimony provided for in the agreement or order. A finding that medical insurance is reasonably available or the child support guidelines schedule in s. 61.30 may constitute changed circumstances. Except as otherwise provided in s. 61.30(11)(c), the court may modify an order of support, maintenance, or alimony by increasing or decreasing the support, maintenance, or alimony retroactively to the date of the filing of the action or supplemental action for modification as equity requires, giving due regard to the changed circumstances or the financial ability of the parties or the child.

(b)1. The court must reduce or terminate an award of support, maintenance, or alimony upon specific written findings by the court that a supportive relationship has existed between the obligee and a person who is not related to the obligee by consanguinity or affinity.

2. In determining the nature of the relationship between an obligee and another person and the extent to which an award of support, maintenance, or alimony should be reduced or terminated because of the existence of a supportive relationship between an obligee and a person who is not related by consanguinity or affinity, the court shall make written findings of fact. The burden is on the obligor to prove, by a preponderance of the evidence, that a supportive relationship exists or has existed in the 365 days before the filing of the petition for dissolution of marriage, separate maintenance, or supplemental petition for modification. If a supportive relationship is proven to exist or to have existed, the burden shifts to the obligee to prove, by a preponderance of the evidence, that the court should not deny or reduce an initial award of support, maintenance, or alimony or reduce or terminate an existing award of support, maintenance, or alimony. The court shall consider and make written findings of fact regarding all relevant facts in s. 61.08(3) and the following additional factors:

a. The extent to which the obligee and the other person have held themselves out as a married couple by engaging in conduct such as using the same last name, using a common mailing address, referring to each other in terms such as “my husband” or “my wife,” or otherwise conducting themselves in a manner that evidences a permanent supportive relationship.

b. The period of time that the obligee has resided with the other person.

c. The extent to which the obligee and the other person have pooled their assets or income, acquired or maintained a joint bank account or other financial accounts, or otherwise exhibited financial interdependence.

d. The extent to which the obligee or the other person has financially supported the other, in whole or in part, including payment of the other’s debts, expenses, or liabilities.

e. The extent to which the obligee or the other person has performed valuable services for the other.

f. The extent to which the obligee or the other person has performed valuable services for the other’s business entity or employer.

g. The extent to which the obligee and the other person have worked together to acquire any assets or to enhance the value of any assets.

h. The extent to which the obligee and the other person have jointly contributed to the purchase of any real or personal property.

i. The extent to which the obligee and the other person have an express or implied agreement regarding property sharing or financial support.

j. The extent to which the obligor has paid the existing alimony award or failed to do so and the existence and amount of any arrearage.

k. The extent to which the obligee and the other person have provided support to the children or other family members of one another, regardless of any legal duty to do so.

3. This paragraph does not abrogate the requirement that every marriage in this state be solemnized under a license, does not recognize a common law marriage as valid, and does not recognize a de facto marriage. This paragraph recognizes that relationships exist that provide financial or economic support equivalent to a marriage and that support, maintenance, or alimony must be modified or terminated if such a relationship is proven to exist. The existence of a conjugal relationship is not necessary for the application of this paragraph.

(c)1. The court may reduce or terminate an award of support, maintenance, or alimony upon specific, written findings of fact that the obligor has reached normal retirement age as defined by the Social Security Administration or the customary retirement age for his or her profession and that the obligor has taken demonstrative and measurable efforts or actions to retire or has actually retired. The burden is on the obligor to prove, by a preponderance of the evidence, that his or her retirement reduces his or her ability to pay support, maintenance, or alimony. If the court determines that the obligor’s retirement has reduced or will reduce the obligor’s ability to pay, the burden shifts to the obligee to prove, by a preponderance of the evidence, that the obligor’s support, maintenance, or alimony obligation should not be terminated or reduced.

2. In determining whether an award of support, maintenance, or alimony should be reduced or terminated because of the obligor’s voluntary retirement, the court shall give consideration to, and make written findings of fact regarding the following factors:

a. The age and health of the obligor.

b. The nature and type of work performed by the obligor.

c. The customary age of retirement in the obligor’s profession.

d. The obligor’s motivation for retirement and likelihood of returning to work.

e. The needs of the obligee and the ability of the obligee to contribute toward his or her own basic needs.

f. The economic impact that a termination or reduction of alimony would have on the obligee.

g. All assets of the obligee and the obligor accumulated or acquired prior to the marriage, during the marriage, or following the entry of the final judgment as well as the obligor and obligee’s respective roles in the wasteful depletion of any marital assets received by him or her at the time of the entry of the final judgment.

h. The income of the obligee and the obligor earned during the marriage or following the entry of the final judgment.

i. The social security benefits, retirement plan benefits, or pension benefits payable to the obligor and the obligee following the final judgment of dissolution.

j. The obligor’s compliance, in whole or in part, with the existing alimony obligation.

3. In reasonable anticipation of retirement, but not more than 6 months before retirement, the obligor may file a petition for modification of his or her support, maintenance, or alimony obligation, which shall be effective upon his or her reasonable and voluntary retirement as determined by the court pursuant to the factors in subparagraph 2. The court shall give consideration to, and make written findings of fact regarding, the factors in subparagraph 2. and s. 61.08(3) when granting or denying the obligor’s petition for modification; when confirming, reducing, or terminating the obligor’s alimony obligation; and when granting or denying any request for modification, the date of filing of the obligor’s modification petition, or other date post-filing as equity requires, giving due regard and consideration to the changed circumstances or the financial ability of the parties.

(d) For each support order reviewed by the department as required by s. 409.2564(11), if the amount of the child support award under the order differs by at least 10 percent but not less than $25 from the amount that would be awarded under s. 61.30, the department shall seek to have the order modified and any modification shall be made without a requirement for proof or showing of a change in circumstances.

(e) The department shall have authority to adopt rules to implement this section.

(2) When an order or agreement is modified pursuant to subsection (1), the party having an obligation to pay shall pay only the amount of support, maintenance, or alimony directed in the new order, and the agreement or earlier order is modified accordingly. No person may commence an action for modification of a support, maintenance, or alimony agreement or order except as herein provided. No court has jurisdiction to entertain any action to enforce the recovery of separate support, maintenance, or alimony other than as herein provided.

(3) This section is declaratory of existing public policy and of the laws of this state.

(4) If a party applies for a reduction of alimony or child support and the circumstances justify the reduction, the court may make the reduction of alimony or child support regardless of whether or not the party applying for it has fully paid the accrued obligations to the other party at the time of the application or at the time of the order of modification.

(5)(a) When a court of competent jurisdiction enters an order for the payment of alimony or child support or both, the court shall make a finding of the obligor’s imputed or actual present ability to comply with the order. If the obligor subsequently fails to pay alimony or support and a contempt hearing is held, the original order of the court creates a presumption that the obligor has the present ability to pay the alimony or support and to purge himself or herself from the contempt. At the contempt hearing, the obligor shall have the burden of proof to show that he or she lacks the ability to purge himself or herself from the contempt. This presumption is adopted as a presumption under s. 90.302(2) to implement the public policy of this state that children shall be maintained from the resources of their parents and as provided for in s. 409.2551, and that spouses be maintained as provided for in s. 61.08. The court shall state in its order the reasons for granting or denying the contempt.

(b) In a proceeding in circuit court to enforce a support order under this chapter, chapter 88, chapter 409, or chapter 742, or any other provision of law, if the court finds that payments due under the support order are delinquent or overdue and that the obligor is unemployed, underemployed, or has no income but is able to work or participate in job training, the court may order the obligor to:

1. Seek employment.

2. File periodic reports with the court, or with the department if the department is providing Title IV-D services, detailing the obligor’s efforts to seek and obtain employment during the reporting period.

3. Notify the court or the department, as appropriate, upon obtaining employment, income, or property.

4. Participate in job training, job placement, work experience, or other work programs that may be available pursuant to chapter 445, chapter 446, or any other source.

An obligor who willfully fails to comply with a court order to seek work or participate in other work-related activities may be held in contempt of court. This paragraph is in furtherance of the public policy of the state of ensuring that children are maintained from the resources of their parents to the extent possible.

(6)(a)1. When support payments are made through the local depository or through the State Disbursement Unit, any payment or installment of support which becomes due and is unpaid under any support order is delinquent; and this unpaid payment or installment, and all other costs and fees herein provided for, become, after notice to the obligor and the time for response as set forth in this subsection, a final judgment by operation of law, which has the full force, effect, and attributes of a judgment entered by a court in this state for which execution may issue. No deduction shall be made by the local depository from any payment made for costs and fees accrued in the judgment by operation of law process under paragraph (b) until the total amount of support payments due the obligee under the judgment has been paid.

2. A certified statement by the local depository evidencing a delinquency in support payments constitute evidence of the final judgment under this paragraph.

3. The judgment under this paragraph is a final judgment as to any unpaid payment or installment of support which has accrued up to the time either party files a motion with the court to alter or modify the support order, and such judgment may not be modified by the court. The court may modify such judgment as to any unpaid payment or installment of support which accrues after the date of the filing of the motion to alter or modify the support order. This subparagraph does not prohibit the court from providing relief from the judgment pursuant to Rule 1.540, Florida Rules of Civil Procedure.

(b)1. When an obligor is 15 days delinquent in making a payment or installment of support and the amount of the delinquency is greater than the periodic payment amount ordered by the court, the local depository shall serve notice on the obligor informing him or her of:

a. The delinquency and its amount.

b. An impending judgment by operation of law against him or her in the amount of the delinquency and all other amounts which thereafter become due and are unpaid, together with costs and a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, for failure to pay the amount of the delinquency.

c. The obligor’s right to contest the impending judgment and the ground upon which such contest can be made.

d. The local depository’s authority to release information regarding the delinquency to one or more credit reporting agencies.

2. The local depository shall serve the notice by mailing it by first-class mail to the obligor at his or her last address of record with the local depository. If the obligor has no address of record with the local depository, service shall be by publication as provided in chapter 49.

3. When service of the notice is made by mail, service is complete on the date of mailing.

(c) Within 15 days after service of the notice is complete, the obligor may file with the court that issued the support order, or with the court in the circuit where the local depository which served the notice is located, a motion to contest the impending judgment. An obligor may contest the impending judgment only on the ground of a mistake of fact regarding an error in whether a delinquency exists, in the amount of the delinquency, or in the identity of the obligor.

(d) The court shall hear the obligor’s motion to contest the impending judgment within 15 days after the date of filing of the motion. Upon the court’s denial of the obligor’s motion, the amount of the delinquency and all other amounts that become due, together with costs and a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, become a final judgment by operation of law against the obligor. The depository shall charge interest at the rate established in s. 55.03 on all judgments for support. Payments on judgments shall be applied first to the current child support due, then to any delinquent principal, and then to interest on the support judgment.

(e) If the obligor fails to file a motion to contest the impending judgment within the time limit prescribed in paragraph (c) and fails to pay the amount of the delinquency and all other amounts which thereafter become due, together with costs and a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, such amounts become a final judgment by operation of law against the obligor at the expiration of the time for filing a motion to contest the impending judgment.

(f)1. Upon request of any person, the local depository shall issue, upon payment of a service charge of up to $25, from which the clerk shall remit $17.50 to the Department of Revenue for deposit into the General Revenue Fund, a payoff statement of the total amount due under the judgment at the time of the request. The statement may be relied upon by the person for up to 30 days from the time it is issued unless proof of satisfaction of the judgment is provided.

2. When the depository records show that the obligor’s account is current, the depository shall record a satisfaction of the judgment upon request of any interested person and upon receipt of the appropriate recording fee. Any person shall be entitled to rely upon the recording of the satisfaction.

3. The local depository, at the direction of the department, or the obligee in a non-IV-D case, may partially release the judgment as to specific real property, and the depository shall record a partial release upon receipt of the appropriate recording fee.

4. The local depository is not liable for errors in its recordkeeping, except when an error is a result of unlawful activity or gross negligence by the clerk or his or her employees.

(g) The local depository shall send the department monthly by electronic means a list of all Title IV-D and non-Title IV-D cases in which a judgment by operation of law has been recorded during the month for which the data is provided. At a minimum, the depository shall provide the names of the obligor and obligee, social security numbers of the obligor and obligee, if available, and depository number.

(7) When modification of an existing order of support is sought, the proof required to modify a settlement agreement and the proof required to modify an award established by court order shall be the same.

(8)(a) When an employee and an employer reach an agreement for a lump-sum settlement under s. 440.20(11), no proceeds of the settlement shall be disbursed to the employee, nor shall any attorney’s fees be disbursed, until after a judge of compensation claims reviews the proposed disbursement and enters an order finding the settlement provides for appropriate recovery of any support arrearage. The employee, or the employee’s attorney if the employee is represented, shall submit a written statement from the department that indicates whether the employee owes unpaid support and, if so, the amount owed. In addition, the judge of compensation claims may require the employee to submit a similar statement from a local depository established under s. 61.181. A sworn statement by the employee that all existing support obligations have been disclosed is also required. If the judge finds the proposed allocation of support recovery insufficient, the parties may amend the allocation of support recovery within the settlement agreement to make the allocation of proceeds sufficient. The Office of the Judges of Compensation Claims shall adopt procedural rules to implement this paragraph.

(b) In accordance with the provisions of s. 440.22, any compensation due or that may become due an employee under chapter 440 is exempt from garnishment, attachment, execution, and assignment of income, except for the purposes of enforcing child or spousal support obligations.

(9) Unless otherwise ordered by the court or agreed to by the parties, the obligation to pay the current child support for that child is terminated when the child reaches 18 years of age or the disability of nonage is removed. The termination of the current child support obligation does not otherwise terminate the obligation to pay any arrearage, retroactive support, delinquency, or costs owed by the obligor.

(10)(a) In a Title IV-D case, if an obligation to pay current child support is terminated due to the emancipation of the child and the obligor owes an arrearage, retroactive support, delinquency, or costs, the obligor shall continue to pay at the same rate in effect immediately prior to emancipation until all arrearages, retroactive support, delinquencies, and costs are paid in full or until the amount of the order is modified. Any income-deducted amount or amount paid by the obligor which is in excess of the obligation to pay current support shall be credited against the arrearages, retroactive support, delinquency, and costs owed by the obligor.

(b) In a Title IV-D case, if an obligation to pay current child support for multiple children is reduced due to the emancipation of one child and the obligor owes an arrearage, retroactive support, delinquency, or costs, the obligor shall continue to pay at the same rate in effect immediately prior to emancipation until all arrearages, retroactive support, delinquencies, and costs are paid in full or until the amount of the order is modified. Any income-deducted amount or amount paid by the obligor which is in excess of the obligation to pay current support shall be credited against the arrearages, retroactive support, delinquency, and costs owed by the obligor. If an obligation to pay current support for more than one child is not reduced when a child is emancipated because the order does not allocate support per child, this paragraph does not apply.

(c) Paragraphs (a) and (b) provide an additional remedy for collection of unpaid support and apply to cases in which a support order was entered before, on, or after July 1, 2004.

(11)(a) A court may, upon good cause shown, and without a showing of a substantial change of circumstances, modify, vacate, or set aside a temporary support order before or upon entering a final order in a proceeding.

(b) The modification of the temporary support order may be retroactive to the date of the initial entry of the temporary support order; to the date of filing of the initial petition for dissolution of marriage, initial petition for support, initial petition determining paternity, or supplemental petition for modification; or to a date prescribed in paragraph (1)(a) or s. 61.30(11)(c) or (17), as applicable.

History.—ss. 1, 2, ch. 16780, 1935; CGL 1936 Supp. 4993(1); s. 16, ch. 67-254; s. 16, ch. 71-241; s. 2, ch. 75-67; s. 124, ch. 86-220; s. 5, ch. 87-95; s. 6, ch. 88-176; s. 14, ch. 91-45; s. 5, ch. 92-138; s. 3, ch. 93-208; s. 335, ch. 95-147; s. 15, ch. 95-222; s. 7, ch. 97-170; s. 40, ch. 98-397; s. 5, ch. 99-375; s. 1, ch. 2001-91; ss. 10, 11, ch. 2001-158; s. 3, ch. 2002-173; s. 73, ch. 2003-402; s. 1, ch. 2004-47; s. 50, ch. 2004-265; s. 4, ch. 2004-334; ss. 5, 6, 7, 8, ch. 2005-39; s. 3, ch. 2005-82; s. 1, ch. 2005-168; s. 11, ch. 2008-61; s. 1, ch. 2008-92; s. 28, ch. 2008-111; s. 16, ch. 2010-187; s. 14, ch. 2019-58; s. 3, ch. 2023-315.

Note.—Former s. 65.15.

F.S. 61.14 on Google Scholar

F.S. 61.14 on Casetext

Amendments to 61.14

Arrestable Offenses / Crimes under Fla. Stat. 61.14

Level: Degree
Misdemeanor/Felony: First/Second/Third

Current data shows no reason an arrest or criminal charge should have occurred directly under Florida Statute 61.14.

Annotations, Discussions, Cases:

Cases from cite.case.law:

E. HOLDER, v. LOPEZ, f k a, 274 So. 3d 518 (Fla. App. Ct. 2019)

. . . See § 61.14(1)(a), Fla. Stat. (2018). . . . 157 So. 3d 332, 337 (Fla. 2d DCA 2015) (mixed standard of review for modifications of alimony under § 61.14 . . . The pertinent portions of section 61.14(1), Florida Statutes, have not been amended since 2003. . . . (listing factors to be considered in evaluating need and ability to pay alimony); § 61.14(1)(a), Fla. . . .

BORDONARO, v. BORDONARO,, 273 So. 3d 225 (Fla. App. Ct. 2019)

. . . . §§ 61.14, 61.30(14), Fla. Stat.; Fla. Fam. L.R.P. 12.285(k). . . .

ZUBRICKY, v. ZUBRICKY,, 273 So. 3d 217 (Fla. App. Ct. 2019)

. . . the Former Wife cohabited with the live-in paramour, making her ineligible for alimony under section 61.14 . . . Did Not Err in Failing to Award Alimony The Former Wife argues the court erred in applying section 61.14 . . . But before addressing section 61.14, the court specifically found the Former Wife did not have the need . . . The Former Wife argues section 61.14 applies only to amend a judgment. . . . As a result, she argues, section 61.14 could not be applied to amend the marital settlement agreement . . .

BMW OF NORTH AMERICA LLC, v. UNITED STATES,, 926 F.3d 1291 (Fed. Cir. 2019)

. . . on "alleged dumping at 254.25 percent, the two individually investigated parties received rates of 61.14 . . . is the same rate received by parties who did not request administrative review and is lower than the 61.14% . . .

PAULETTE, v. ROSELLA,, 267 So. 3d 571 (Fla. App. Ct. 2019)

. . . First, section 61.14(1)(a), Florida Statutes (2017), provides in pertinent part: When the parties enter . . . , with due regard to the ... changed financial abilities of the parties" in accordance with section 61.14 . . .

SILVA, v. H. SILVA,, 273 So. 3d 116 (Fla. App. Ct. 2019)

. . . substantial change in circumstances requiring an increase in the father's child support obligation, see § 61.14 . . .

INMAN, v. INMAN,, 260 So. 3d 555 (Fla. App. Ct. 2018)

. . . He alternatively sought modification under section 61.14(1)(a), Florida Statutes (2016), based on the . . . imposed a heavier burden than that required by law in denying the request for modification under section 61.14 . . . The Former Husband alternatively sought modification under section 61.14(1)(a), based on the changed . . . the same regardless of whether the award was established by court order or settlement agreement. § 61.14 . . . However, as our sister courts have recognized, we are bound by the language of section 61.14(7). . . .

WINDSOR, v. WINDSOR,, 262 So. 3d 853 (Fla. App. Ct. 2018)

. . . been a substantial change in circumstances-a prerequisite to any change in support obligations, see § 61.14 . . .

NUTTLE, v. NUTTLE,, 257 So. 3d 1084 (Fla. App. Ct. 2018)

. . . . § 61.14(1)(a), Fla. Stat. (2016). In Thyrre v. . . .

SHAARBAY, v. ALVAREZ,, 255 So. 3d 487 (Fla. App. Ct. 2018)

. . . See § 61.14(6)(a)3., Fla. . . .

W. BAUCHMAN, v. BAUCHMAN,, 253 So. 3d 1143 (Fla. App. Ct. 2018)

. . . ." § 61.14(1)(a), Fla. Stat. (2017). . . .

D. DEMMING, v. D. DEMMING,, 251 So. 3d 284 (Fla. App. Ct. 2018)

. . . See, e.g., §§ 61.13, 61.14, Fla. . . .

MALOWNEY, v. MALOWNEY,, 250 So. 3d 204 (Fla. App. Ct. 2018)

. . . See § 61.14(1)(a), Fla. Stat. (2016) ; see also Wolfe v. . . . 61.08(2) factors in determining alimony must be considered in modification proceedings under section 61.14 . . .

GELBER, f k a v. BRYDGER,, 248 So. 3d 1170 (Fla. App. Ct. 2018)

. . . Concerning modifications of support, maintenance, and alimony agreements or orders, section 61.14(1)( . . . The MSA made alimony "modifiable in accordance with Florida Statutes" and section 61.14(1)(a) makes alimony . . .

ISPASS, v. B. ISPASS,, 243 So. 3d 453 (Fla. App. Ct. 2018)

. . . The trial court determined that it lacked subject matter jurisdiction, reasoning that section 61.14, . . . Section 61.14(1)(a) specifically grants circuit courts the authority to hear modification of alimony . . . cases in the circuit in which the agreement was executed. § 61.14(1)(a), Fla. . . . See § 61.14(1)(a), Fla. Stat. (2003) ; Paulk v. Paulk , 504 So.2d 790, 790 (Fla. 1st DCA 1987). . . . Although these are older cases, the relevant statutory language of section 61.14 remains the same. . . .

BRUCE, v. BRUCE,, 243 So. 3d 461 (Fla. App. Ct. 2018)

. . . Florida's supportive relationship statute, section 61.14(1)(b), Florida Statutes (2015 ), is not applicable . . . However, the factors found in section 61.14(1)(b) provide the trial court with a useful framework to . . .

IN RE AMENDMENTS TO THE FLORIDA SUPREME COURT APPROVED FAMILY LAW FORMS- NOMENCLATURE, 235 So. 3d 357 (Fla. 2018)

. . . Supportive Relationship—a relationship, defined in section 61.14(l)(b)l, Florida Statutes, existing between . . .

E. DOGODA, Jr. v. DOGODA,, 233 So. 3d 484 (Fla. Dist. Ct. App. 2017)

. . . . § 61.14(l)(a), Fla. Stat. (2015). . . . agreement and the proof required to modify an award established by court order shall be the same.” § 61.14 . . . “Section 61.14 ;.. extends jurisdiction to the trial courts to ’make orders as equity requires’ to modify . . . Mouton, 590 So.2d 40, 41 (Fla. 2d DCA 1991) (quoting § 61.14(1), Florida- Statutes (1989)). . . .

BROGA, v. BROGA,, 227 So. 3d 239 (Fla. Dist. Ct. App. 2017)

. . . See § 61.14, Fla. Stat. (2017). . . .

KALLETT, v. KASTRINER,, 225 So. 3d 967 (Fla. Dist. Ct. App. 2017)

. . . statutory right to seek modification, we reverse and remand for further proceedings pursuant to section 61.14 . . . Section 61.14(l)(a) allows a party to apply to a circuit court for an order modifying an alimony obligation . . . trial court to reinstate the Former Husband’s petition and for further proceedings pursuant to section 61.14 . . .

IN RE ROSELLI MOVING STORAGE CORP., 568 B.R. 592 (Bankr. E.D.N.Y. 2017)

. . . , that the Trustee is awarded commissions in the amount of $9,572.20 and expenses in the amount of $61.14 . . .

DEPARTMENT OF REVENUE O B O TISDALE, v. L. JACKSON,, 217 So. 3d 192 (Fla. Dist. Ct. App. 2017)

. . . Stat. (2015); see also § 61.14(9), Fla. . . .

P. REGAN, v. REGAN,, 217 So. 3d 91 (Fla. Dist. Ct. App. 2017)

. . . Section 61.14, Florida Statutes (2015), provides for the ability to modify alimony and support which . . . confirming the amount of separate support, maintenance, or alimony provided for in the agreement or order. § 61.14 . . . agreement and the proof required to modify an award established by court order shall be the same. § 61.14 . . . alimony “as equity requires, with due regard to the changed circumstances or financial ability[,]” § 61.14 . . . Given the broad discretion which section 61.14(l)(a) gives the trial judge to make a reduction, “as equity . . .

RIDDLE, v. RIDDLE, 214 So. 3d 694 (Fla. Dist. Ct. App. 2017)

. . . (providing the standard for modification of a parenting plan in a final judgment of dissolution); § 61.14 . . .

BMW OF NORTH AMERICA LLC, v. UNITED STATES,, 208 F. Supp. 3d 1388 (Ct. Int'l Trade 2017)

. . . petition alleged dumping at 254.25 percent, the two individually investigated parties received rates of 61.14 . . .

ALLSTAR MARKETING GROUP, LLC, v. UNITED STATES,, 211 F. Supp. 3d 1319 (Ct. Int'l Trade 2017)

. . . Pursuant to EN 61.14, heading 6114 covers: (1) Aprons, boiler suits (coveralls), smocks and other protective . . . When the nature of the article is unclear, EN 61.14 describes the article by reference to an identifiable . . .

ALABAMA LEGISLATIVE BLACK CAUCUS, v. ALABAMA, v., 231 F. Supp. 3d 1026 (M.D. Ala. 2017)

. . . 2), and 61 percent black, (Doc. 296-1 at 3); the McClammy Plan had a black population percentage of 61.14 . . .

LOFTIS, v. C. LOFTIS,, 208 So. 3d 824 (Fla. Dist. Ct. App. 2017)

. . . and that Former Wife could seek relief by filing a petition for modification pursuant • to section 61.14 . . .

RANDALL, v. GRIFFIN, Jr., 204 So.3d 965 (Fla. Dist. Ct. App. 2016)

. . . See § 61.14(5)(b), Fla. Stat. (2015). . . . Furthermore, the trial court shall comply with Florida Family Law Rule of Procedure 12.615(d) and section 61.14 . . .

BERGER, v. BERGER,, 201 So. 3d 819 (Fla. Dist. Ct. App. 2016)

. . . may be modified or terminated based upon a substantial change in circumstances in accordance with s.61.14 . . . substantial change in circumstances or upon the existence of a supportive relationship in accordance with s.61.14 . . .

BLOOM, v. PANCHYSHYN,, 200 So. 3d 272 (Fla. Dist. Ct. App. 2016)

. . . orders terminate when the child turns 18 “unless the court finds ... that [section] 743.07(2) applies”), 61.14 . . .

C. ROSENTHAL, v. A. ROSENTHAL,, 199 So. 3d 541 (Fla. Dist. Ct. App. 2016)

. . . Section 61.14(l)(a), Florida Statutes (2013), allows for the modification of a marital settlement agreement . . .

DEPARTMENT OF REVENUE, v. LLAMAS, 196 So. 3d 1267 (Fla. Dist. Ct. App. 2016)

. . . .; see also § 61.14(l)(a), Fla. Stat. . . .

BACHMAN, v. McLINN,, 197 So. 3d 123 (Fla. Dist. Ct. App. 2016)

. . . See § 61.14(l)(a), Fla. . . .

J. MARTIN, v. L. ROBBINS a k a L., 194 So. 3d 563 (Fla. Dist. Ct. App. 2016)

. . . . § 61.14(l)(b), Fla. Stat. (2015). . . . Section 61.14, Florida Statutes (2015), sets out circumstances that a trial court shall weigh in making . . . The extent to which the obligee or the other person has supported the other, in whole or, in part. § 61.14 . . .

HARITOS, v. HARITOS n k a, 193 So. 3d 1050 (Fla. Dist. Ct. App. 2016)

. . . jurisdiction to rule on the issues of child support and alimony is set forth in sections 61.13 and 61.14 . . . Overbey, 698 So.2d 811, 813 (Fla.1997) (“Generally, under [sections 61.13 and 61.14], a fundamental prerequisite . . . vacate, or set aside a temporary support order before or upon entering a final order in a proceeding.” § 61.14 . . .

TOWNSEND, v. R. J. REYNOLDS TOBACCO COMPANY,, 192 So. 3d 1223 (Fla. 2016)

. . . the judgment is paid, except for judgments1 entered by the clerk of the court pursuant to ss. 55.141, 61.14 . . .

IVANOVICH, v. VALLADAREZ,, 190 So. 3d 1144 (Fla. Dist. Ct. App. 2016)

. . . father when father’s petition for modification of child support was filed five months later); see also § 61.14 . . .

POLLACK, v. S. POLLACK,, 181 So. 3d 1287 (Fla. Dist. Ct. App. 2015)

. . . . - See § 61.14(1)(b), Fla, Stat. (2015). . . .

In AMENDMENTS TO FLORIDA SUPREME COURT APPROVED FAMILY LAW FORMS, 205 So. 3d 1 (Fla. 2015)

. . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . .

TIMMONS, v. TIMMONS,, 179 So. 3d 380 (Fla. Dist. Ct. App. 2015)

. . . See, e.g., § 61.14, Fla. Stat. . . .

MIGGINS, v. MIGGINS,, 177 So. 3d 315 (Fla. Dist. Ct. App. 2015)

. . . substitute language referring to the “existence of a supportive relationship” in accordance with section 61.14 . . .

DEPARTMENT OF REVENUE, v. WOLF, 164 So. 3d 101 (Fla. Dist. Ct. App. 2015)

. . . , whether done by a circuit judge or an administrative court, are governed by sections 409.2563 and 61.14 . . . At this juncture, we run squarely into potentially conflicting language in sections 409.2563 and 61.14 . . . The Department points to section 61.14, entitled “Enforcement and modification of support, maintenance . . . But for the word “prospectively” in subsection 409.2563(12), the two statutory frameworks — 61.14(l)( . . . In cases like the present one, subsection 61.14(l)(a) allows modifications to potentially extend back . . .

R. J. REYNOLDS TOBACCO COMPANY, v. TOWNSEND,, 160 So. 3d 570 (Fla. Dist. Ct. App. 2015)

. . . the judgment is paid, except for judgments entered by the clerk of the court pursuant to ss. 55.141, 61.14 . . .

In AMENDMENTS TO FLORIDA SUPREME COURT APPROVED FAMILY LAW FORMS, 173 So. 3d 19 (Fla. 2015)

K. ROCK, v. DEPARTMENT OF REVENUE,, 159 So. 3d 287 (Fla. Dist. Ct. App. 2015)

. . . [P]ursuant to section 61.14(l)(a), a parent seeking modification of child support payments because he . . .

La S. FAULK, v. STATE DEPARTMENT OF REVENUE,, 157 So. 3d 534 (Fla. Dist. Ct. App. 2015)

. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . . The first paragraph of the pleading cites section 61.14(1), Florida Statutes, which discusses modification . . .

D. ATKINSON, v. L. ATKINSON,, 157 So. 3d 473 (Fla. Dist. Ct. App. 2015)

. . . findings that the Former Wife was not engaged in a “supportive relationship” within the meaning of section 61.14 . . . In addressing this question, we need not consider the application of section 61.14(1)(b). . . . The legislature enacted section 61.14(1)(b) in 2005 to “provide an alternate method to a court to reduce . . . In accordance with section 61.14(1)(b)(1), “[t]he court may reduce or terminate an award of alimony upon . . . See also Buxton, 963 So.2d at 951-52 (discussing section 61.14(1)(b) and the Senate Staff Analysis of . . .

M. JARRARD, v. T. JARRARD,, 157 So. 3d 332 (Fla. Dist. Ct. App. 2015)

. . . court’s conclusion that the former wife was not engaged in a “supportive relationship” under section 61.14 . . . Jarrard in this case, seek modification of alimony under section 61.14, Florida Statutes (2012). . . . If the trial court decides to modify alimony, section 61.14(l)(a) authorizes a modification retroactive . . . In this case, section 61.14(l)(a) would appear to give the trial court discretion to adjust alimony to . . .

WOOD, v. BLUNCK,, 152 So. 3d 693 (Fla. Dist. Ct. App. 2014)

. . . Galligher, 527 So.2d 858, 860 (Fla. 1st DCA 1988); § 61.14(1), Fla. Stat. (2009). . . .

A. ELLISEN, v. L. ELLISEN,, 150 So. 3d 1270 (Fla. Dist. Ct. App. 2014)

. . . Tobin, 201 So.2d 799, 800-01 (Fla. 3d DCA 1967)); see also § 61.14, Fla. . . . Since then, section 61.14, Florida Statutes has stated, “When modification of an existing order of support . . . agreement and the proof required to modify an award established by court order shall be the same.” § 61.14 . . .

VICTORIA S SECRET DIRECT, LLC, v. UNITED STATES, v., 769 F.3d 1102 (Fed. Cir. 2014)

. . . Explanatory Note 61.14. . . .

DEPARTMENT OF REVENUE o b o v. SECOR,, 146 So. 3d 1250 (Fla. Dist. Ct. App. 2014)

. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . .

F. ELBAUM, v. J. ELBAUM,, 141 So. 3d 658 (Fla. Dist. Ct. App. 2014)

. . . Under section 61.14(l)(b)l., Florida Statutes (2012), a court may reduce or terminate alimony if “a supportive . . . As we have explained: [Sjection 61.14(l)(b) requires the court to determine if an alimony obligee has . . . Section 61.14(l)(b) is actually a codification of prior case law which held that, in post dissolution . . .

BARATTA T. P. A. v. COSTA- MARTINEZ,, 139 So. 3d 407 (Fla. Dist. Ct. App. 2014)

. . . See § 61.14(5)(a), Fla. . . .

HOROWITZ, v. HOROWITZ,, 139 So. 3d 929 (Fla. Dist. Ct. App. 2014)

. . . See § 61.14(1)(a), Fla. Stat. (2013). . . .

W. GARVEY, v. GARVEY,, 138 So. 3d 1115 (Fla. Dist. Ct. App. 2014)

. . . Section 61.14(1)(a), Florida Statutes, governs modification of support and provides the following in . . . requires, with due regard to the changed circumstances or the financial abilities of the parties .... § 61.14 . . . agreement and the proof required to modify an award established by court order shall be the same.” § 61.14 . . . Pratt, 645 So.2d 510, 511 n. 1 (Fla. 3d DCA 1994) (recognizing that section 61.14, Florida Statutes, . . . burden of proof to apply to modification of alimony set by agreement and alimony set by the court); § 61.14 . . .

L. HAHAMOVITCH n k a v. H. HAHAMOVITCH,, 133 So. 3d 1008 (Fla. Dist. Ct. App. 2014)

. . . settling alimony rights is subject to increase or decrease under changed conditions as provided in section 61.14 . . .

F. GREGORY, Jr. v. GREGORY,, 128 So. 3d 926 (Fla. Dist. Ct. App. 2013)

. . . A review of a trial court’s decision under section 61.14(l)(b), Florida Statutes (2012), is a mixed question . . .

B. MURPHY, v. J. MURPHY,, 201 So. 3d 18 (Fla. Dist. Ct. App. 2013)

. . . Mark Llerena (“Llerena”) were involved in a “supportive relationship” within the meaning of section 61.14 . . . or the financial ability of either party changes ....”§ 61.14(l)(a); see also King, 82 So.3d at 1131 . . . To obtain a modification under section 61.14(l)(a), the trial court must make a determination that: ( . . . Section 61.14(l)(b) provides, in relevant part, as follows: 1. . . . See §. 61.14(l)(b)2.d., e.,.k. . . .

In AMENDMENTS TO FLORIDA SUPREME COURT APPROVED FAMILY LAW FORMS, 122 So. 3d 320 (Fla. 2013)

. . . Supportive Relationship — a relationship, defined in section 61.14(l)(b)l, Florida Statutes, existing . . . substantial change in circumstances, or the existence of a supportive relationship in accordance with section 61.14 . . . substantial change in circumstances or the existence of a supportive relationship in accordance with section 61.14 . . .

R. TARKOW, n k a v. A. TARKOW,, 128 So. 3d 82 (Fla. Dist. Ct. App. 2013)

. . . also alleged that the Former Wife was in a “supportive relationship” within the meaning of section 61.14 . . . In addition, based on the evidence and a review of the factors outlined in section 61.14(l)(b)(2), the . . .

R. HOOVER, v. FLORIDA DEPARTMENT OF REVENUE D. MITCHELL,, 114 So. 3d 494 (Fla. Dist. Ct. App. 2013)

. . . . § 61.14(ll)(b). . . .

VICTORIA S SECRET DIRECT, LLC, v. UNITED STATES,, 908 F. Supp. 2d 1332 (Ct. Int'l Trade 2013)

. . . EN 61.14. The Bra Top is not described by the terms of any heading in the group 6101-6113, HTSUS. . . . See' EN 62.11 (“[U]nlike heading 61.14 this heading also covers tailored waistcoats separately presented . . .

LERNER NEW YORK, INC. v. UNITED STATES,, 908 F. Supp. 2d 1313 (Ct. Int'l Trade 2013)

. . . EN 61.14. . . .

MANN, Sr. v. A. YEATTS,, 111 So. 3d 934 (Fla. Dist. Ct. App. 2013)

. . . Mann filed his petition for modification of a paternity support order, pursuant to section 61.14, Florida . . . Yeatts’ counsel specifically argued that section 61.14 did not apply to the case because it was a paternity . . . proper in Putnam County because a modification of a paternity support order is maintained under section 61.14 . . .

RIDDELL, INC. v. UNITED STATES,, 906 F. Supp. 2d 1355 (Ct. Int'l Trade 2013)

. . . Explanatory Notes to Heading 61.14 (2012). . . . football and therefore classifiable under subheading 6114.30.30); see also Explanatory Notes to Heading 61.14 . . .

SMITH, v. SMITH,, 110 So. 3d 108 (Fla. Dist. Ct. App. 2013)

. . . or modify an obligation to pay alimony by invoking Florida’s supportive relationship statute section 61.14 . . . Smith, was in a supportive relationship as defined under Florida’s supportive relationship statute. § 61.14 . . . Florida’s supportive relationship statute section 61.14(l)(b), “is actually a codification of prior case . . . Florida’s statute section 61.14 provides in pertinent part: The court may reduce or terminate an award . . . supportive relationship has existed between the obligee and a person with whom the obligee resides. 61.14 . . .

OZUNA, v. SHEARD,, 109 So. 3d 1176 (Fla. Dist. Ct. App. 2013)

. . . Section 61.14(a), Florida Statutes (2012), specifically permits a child support modification action to . . . Section 61.14(l)(a), provides, in pertinent part: When the parties enter into an agreement, for payments . . .

BROEMER, v. BROEMER,, 109 So. 3d 284 (Fla. Dist. Ct. App. 2013)

. . . substantial change in circumstances or upon the existence of a supportive relationship in accordance ■with s. 61.14 . . .

SCHECTER, v. SCHECTER,, 109 So. 3d 833 (Fla. Dist. Ct. App. 2013)

. . . Section 61.14(ll)(a), of the Florida Statutes provides that “[a] court may, upon good cause shown, and . . .

P. VAN LOOVEN, Jr. v. A. VAN LOOVEN,, 100 So. 3d 148 (Fla. Dist. Ct. App. 2012)

. . . Under section 61.14(1)(a), Florida Statutes (2010), a party who is required to pay child support may . . . Section 61.14(1)(a) provides only these bases for requesting modification, and, as to change in circumstances . . . After confirming the permissible grounds in section 61.14(1)(a) for requesting modification, the court . . . Reading sections 61.13(1)(a) and 61.14(1)(a) in pari materia, the supreme court concluded that “the father . . .

MASON, v. JANSSEN,, 113 So. 3d 41 (Fla. Dist. Ct. App. 2012)

. . . See § 61.14(l)(a), Fla. . . .

COOK, v. T. COOK, Jr., 94 So. 3d 683 (Fla. Dist. Ct. App. 2012)

. . . Under section 61.14, Florida Statutes (2011), statutory modification is available to a former spouse . . . there was no basis for the former wife’s claim and remand for further proceedings pursuant to section 61.14 . . .

T. WIESENFELD, v. WIESENFELD,, 95 So. 3d 959 (Fla. Dist. Ct. App. 2012)

. . . . § 61.14(1), Fla. Stat. (2010); Pimm v. Pimm, 601 So.2d 534, 536 (Fla.1992). . . . requires, giving due regard to the changed circumstances or the financial ability of the parties.” § 61.14 . . .

KOSKI, v. KOSKI,, 98 So. 3d 93 (Fla. Dist. Ct. App. 2012)

. . . all applicable section 61.08(2) factors must be considered in modification proceedings under section 61.14 . . .

OVERTON, v. OVERTON,, 92 So. 3d 253 (Fla. Dist. Ct. App. 2012)

. . . cohabited with a third party, with whom she was in a supportive relationship within the meaning of section 61.14 . . . Section 61.14(l)(b) recognizes the economic support that occurs when independent individuals cho[o]se . . . previously expressly held that, when deciding whether to reduce or terminate alimony under section 61.14 . . . the economic factors enumerated in section 61.08(2) apply to modification proceedings under section 61.14 . . . supportive relationship has existed between the obligee and a person with whom the obligee resides.” § 61.14 . . .

M. MORRELL, v. A. MORRELL,, 113 So. 3d 857 (Fla. Dist. Ct. App. 2012)

. . . See § 61.14(l)(b)(l), Fla. . . . remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances.” § 61.14 . . .

H. KING, v. L. KING,, 82 So. 3d 1124 (Fla. Dist. Ct. App. 2012)

. . . Subsection (b) of section 61.14(1) is sometimes referred to as “the cohabitation statute.” . . . The legislature added subsection (b) to section 61.14(1) in 2005. . . . First, the circuit court must “elicit the nature and extent of the relationship in question.” § 61.14 . . . When the legislature enacted subsection (b) in 2005, it added the new law to section 61.14(1). . . . Hosford, 362 So.2d 973 (Fla. 1st DCA 1978) and § 61.14, Fla. Stat. (2004)). . . .

WALKER, v. A. WALKER,, 80 So. 3d 1128 (Fla. Dist. Ct. App. 2012)

. . . See § 61.14(l)(a), Fla. Stat. (2010); see also Wiele v. . . . Section 61.14(l)(a), which allows a court to “modify an order of support, maintenance or alimony,” empowers . . .

NABINGER, n k a v. H. NABINGER, II,, 82 So. 3d 1075 (Fla. Dist. Ct. App. 2011)

. . . .; see also, § 61.14, Fla. Stat. (equitable result desired in modification proceedings). . . .

M. HERNANDEZ, v. FRONTIERO,, 73 So. 3d 875 (Fla. Dist. Ct. App. 2011)

. . . See § 61.14(5)(a), Fla. . . .

A. BROWN, v. BROWN,, 68 So. 3d 964 (Fla. Dist. Ct. App. 2011)

. . . Section 61.14(l)(a), Florida Statutes (2009), gives the trial court broad authority to enter orders enforcing . . .

DEPARTMENT OF REVENUE, v. S. MARTIN,, 65 So. 3d 603 (Fla. Dist. Ct. App. 2011)

. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . .

J. ELLIOTT, IV, v. BRADSHAW,, 59 So. 3d 1182 (Fla. Dist. Ct. App. 2011)

. . . Pursuant to section 61.14(5)(a), Florida Statutes (2010), husband is presumed to have a continuing ability . . . Bieluch, 814 So.2d 448 (Fla. 4th DCA 2001) (recognizing that section 61.14(5)(a) controls the burden . . . conclusory finding that husband had the present ability to pay and noting that the presumption of section 61.14 . . .

A. MORRISON, v. M. MORRISON, n k a M., 60 So. 3d 410 (Fla. Dist. Ct. App. 2011)

. . . . § 61.14(l)(a), Fla. Stat. (2006); Bedell v. Bedell, 583 So.2d 1005, 1007 (Fla.1991). . . . Rather, based on the language contained in section 61.14(l)(a) and the supreme court’s analysis in Bedell . . . here and in Eisemann, a party will be precluded from seeking modification, notwithstanding section 61.14 . . . In summary, the situation here reflects changed circumstances as contemplated by section 61.14(l)(a), . . . Modification Pursuant to section 61.14(l)(a), Florida Statutes (2006), “[when] the parties enter into . . .

R. WEBBER, v. A. WEBBER,, 56 So. 3d 822 (Fla. Dist. Ct. App. 2011)

. . . See § 61.14(l)(a), Fla. . . .

DELATE, v. ILER,, 50 So. 3d 1242 (Fla. Dist. Ct. App. 2011)

. . . Kusick, 944 So.2d 1081, 1082 (Fla. 2d DCA 2006), and citing section 61.14, Florida Statutes). . . .

In AMENDMENTS TO THE FLORIDA SUPREME COURT APPROVED FAMILY LAW FORMS, 59 So. 3d 792 (Fla. 2010)

. . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . .

GERGEN, v. R. GERGEN,, 48 So. 3d 148 (Fla. Dist. Ct. App. 2010)

. . . review, and provides no basis upon which modification might be sought in the future pursuant to section 61.14 . . .

In AMENDMENTS TO THE FLORIDA FAMILY LAW RULES, 55 So. 3d 381 (Fla. 2010)

. . . See also section 61.14, Florida Statutes and rule 12.615, Florida Family Law Rules of Procedure. . . .

MORRIS, v. MORRIS,, 42 So. 3d 341 (Fla. Dist. Ct. App. 2010)

. . . The trial court, after using the criteria set forth in section 61.14(l)(b)2., Florida Statutes (2007) . . .

SUAREZ, v. SANCHEZ,, 43 So. 3d 118 (Fla. Dist. Ct. App. 2010)

. . . Kusick, 944 So.2d 1081, 1082 (Fla. 2d DCA 2006); see also § 61.14(l)(a), Fla. . . .

BIEDA, v. BIEDA, 42 So. 3d 859 (Fla. Dist. Ct. App. 2010)

. . . Although section 61.14(6)(a)(l), Florida Statutes (2009), provides for a summary procedure in which delinquent . . .

DEPARTMENT OF REVENUE, o b o GAUTHIER, v. HOOVER,, 40 So. 3d 99 (Fla. Dist. Ct. App. 2010)

. . . administrative support order may not be retroactively modified by the circuit court, except as provided by s. 61.14 . . .

WARFEL, v. UNIVERSAL INSURANCE COMPANY OF NORTH AMERICA,, 36 So. 3d 136 (Fla. Dist. Ct. App. 2010)

. . . Jenne, 721 So.2d 380, 383 (Fla. 4th DCA 1998) (discussing amendment to section 61.14, Florida Statutes . . .

OVERTON, v. OVERTON,, 34 So. 3d 759 (Fla. Dist. Ct. App. 2010)

. . . See § 61.14(l)(b)(l)-(2), Florida Statutes (2007); French v. . . . Section 61.14(l)(b)(l) provides that, upon specific findings that a supportive relationship exists between . . . Section 61.14(l)(b)(2) delineates factors that the trial court “shall give consideration to” when determining . . . Section 61.14(l)(b) recognizes the economic support that occurs when independent individuals chose to . . . the instant case, the trial court did not make any findings regarding the factors outlined in section 61.14 . . .

M. WILSON, v. S. WILSON, DVM., 37 So. 3d 877 (Fla. Dist. Ct. App. 2010)

. . . Analysis Section 61.14, Florida Statutes (2007), provides in relevant part as follows: (l)(a) When the . . . See § 61.14(l)(a); Chambliss v. Chambliss, 921 So.2d 822, 824 (Fla. 2d DCA 2006). Affirmed. . . .

VOLLMER, v. VOLLMER,, 33 So. 3d 67 (Fla. Dist. Ct. App. 2010)

. . . See § 61.14(1); Hudson-McCann v. McCann, 8 So.3d 1228, 1230 (Fla. 5th DCA 2009). . . .

SCHMACHTENBERG n k a v. C. SCHMACHTENBERG,, 34 So. 3d 28 (Fla. Dist. Ct. App. 2010)

. . . Here, the trial court, invested with authority by section 61.14(l)(a), Florida Statutes, made a modification . . .