Crisoforo Estrada, Jr. v. Ana Luz Garcia

• Court: District Court of Appeal of Florida
• Decided: February 18, 2026
• Docket: 3D2025-0101
• Status: Published

Opinion

Third District Court of Appeal State of Florida

Opinion filed February 18, 2026. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D25-0101 Lower Tribunal No. 21-24496 FC 02 ________________

Crisoforo Estrada, Jr., Appellant,

vs.

Ana Luz Garcia, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Stacy D. Glick, Judge.

Sandy T. Fox, P.A., and Sandy T. Fox, for appellant.

No appearance, for appellee.

Before EMAS, GORDO and BOKOR, JJ.

BOKOR, J. Crisoforo Estrada, the former husband, appeals an amended final

judgment of dissolution. His unopposed brief highlights several errors and

omissions in the judgment, including a failure to consider all required factors

before rendering an unequal distribution and alimony award. See §

61.075(3), Fla. Stat. (“[A]ny distribution of marital assets or marital liabilities

shall be supported by factual findings in the judgment or order based on

competent substantial evidence with reference to the factors enumerated in

subsection (1). The distribution of all marital assets and marital liabilities,

whether equal or unequal, shall include specific written findings of fact as to

the following . . . .”); § 61.08(2)(b), Fla. Stat. (“When determining a support,

maintenance, or alimony claim, the court shall include written findings of fact

relative to the factors provided in subsection (3) supporting an award or

denial of support, maintenance, or alimony . . . .”).

“Failure to make statutory findings is reversible error.” Rojas v. Otero,

399 So. 3d 1160, 1163 (Fla. 3d DCA 2024). Thus, we reverse and remand

for the trial court to make specific findings in accordance with sections 61.075

and 61.08.

Reversed and remanded.