Leonard Brandon Pringle v. Ingrid Esther Pringle
This text of Leonard Brandon Pringle v. Ingrid Esther Pringle (Leonard Brandon Pringle v. Ingrid Esther Pringle) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
Third District Court of Appeal State of Florida
Opinion filed December 13, 2023. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D22-1464 Lower Tribunal No. 17-21846 ________________
Leonard Brandon Pringle, Appellant,
vs.
Ingrid Esther Pringle, Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Jason E. Dimitris, Judge.
Sandy T. Fox, P.A., and Sandy T. Fox and Alisha B. Savani, for appellant.
Florida Appeals, and Erin Pogue Newell and Shannon McLin, B.C.S. (Orlando), for appellee.
Before LOGUE, C.J., and LOBREE and BOKOR, JJ.
LOGUE, C.J.
Former Husband, Leonard Brandon Pringle, appeals the trial court’s
post-judgment orders unequally distributing the mortgage debt he and his Former Wife, Ingrid Esther Pringle, shared on their marital home. He argues
the trial court abused its discretion in doing so.
This is not the first time this issue has been before us. The trial court
entered the orders on appeal pursuant to our prior opinion. Pringle v. Pringle,
333 So. 3d 757, 758 (Fla. 3d DCA 2022). In this opinion, we reviewed the
Former Husband’s appeal of the final judgment, which challenged the trial
court’s distribution of the mortgage debt. Id. However, we held that we could
not review this issue because the trial court did not actually decide it. Id. So,
we remanded on this issue and instructed the trial court to rule on it. Id.
The trial court did so and entered orders distributing the entire
mortgage debt to the Former Husband. The Former Husband now appeals
these orders, arguing that the trial court abused its discretion when it
distributed the entire mortgage debt to him. We are not persuaded.
The law in this area is clear, the distribution of a martial asset or liability
does not have to be equal. While there is a statutory presumption in favor of
equal distribution, distribution is ultimately a discretionary function of the trial
court, based on its evaluation of the factors in § 61.075(1), Florida Statutes.
Although the discretion of the trial court in disposing of marital property is tempered by Florida's statutory presumption in favor of equal distribution, the law recognizes there are certain instances where “there is a justification for unequal distribution based on all the relevant factors.” In accord with these principles,
2 “a trial court need not equalize the financial position of the parties” but must “ensure that neither spouse passes automatically from misfortune to prosperity or from prosperity to misfortune.”
Corrales v. Corrales, 320 So. 3d 217, 220 (Fla. 3d DCA 2021) (quoting §
61.075(1), Fla. Stat. and Canakaris v. Canakaris, 382 So. 2d 1197, 1204
(Fla. 1980)).
In its judgment, the trial court made lengthy findings pursuant to §
61.075(1), Florida Statutes, detailing the intentional conduct of the Former
Husband that resulted in its decision to unequally distribute the interests in
the marital home.1 In particular, it mentions the Former Husband ousting the
Former Wife from the home, resulting in her having to pay for a new place to
live while also depriving her of the opportunity to collect rent from the third
parties the Former Husband unilaterally allowed to live there after she left.
We find no abuse of discretion in the trial court’s determination that these
actions justified an unequal distribution.
Affirmed.
1 At a hearing on remand, the trial court explained that its reasons for unequally distributing the marital home’s mortgage debt were the same as its reasons for unequally distributing the home’s equity. These reasons were laid out in the trial court’s final judgment.
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