Linstroth v. Dorgan

2 So. 3d 305, 2008 Fla. App. LEXIS 8434, 2008 WL 2356760
CourtDistrict Court of Appeal of Florida
DecidedJune 11, 2008
Docket4D07-1493, 4D07-3469
StatusPublished
Cited by8 cases

This text of 2 So. 3d 305 (Linstroth v. Dorgan) 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.

Bluebook
Linstroth v. Dorgan, 2 So. 3d 305, 2008 Fla. App. LEXIS 8434, 2008 WL 2356760 (Fla. Ct. App. 2008).

Opinions

DAVIDSON, LISA, Associate Judge.

These former spouses divorced in 1992. At that time, the trial court judge awarded the former wife $2,775 per month as permanent periodic alimony. In 2002, the former wife began cohabiting with James Stewart. One year later, the parties consented to an agreed order reducing alimony to $1,550 per month. Two years after that, the former husband brought this proceeding to reduce or terminate his alimony obligation, citing the recent enactment of section 61.14(l)(b), Florida Statutes (2005). The former wife countered with a request to return the amount of alimony to its original level of $2,775 per month. The trial court judge entered a final order denying termination and any reduction of alimony and granting the former wife’s request.

In 2005, the Florida Legislature enacted section 61.14(l)(b) which permits a court to reduce or terminate an award of alimony “upon specific written findings by the court that since the granting of a divorce and the award of alimony a supportive relationship has existed between the obli-gee and a person with whom the obligee resides.” “Supportive relationship” is not defined in the statute but the purpose of the statute is summarized as follows:

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 only that relationships do exist that provide economic support equivalent to a marriage and that alimony terminable on remarriage may be reduced or terminated upon the establishment of equivalent equitable circumstances as described in this paragraph.

§ 61.14(l)(b)3., Fla. Stat. (2005). The standard of review in determining what constitutes a “supportive relationship” as contemplated by section 61.14 is de novo since it requires the court to interpret the applicable law. See Chrestensen v. Eurogest, Inc., 906 So.2d 343, 344 (Fla. 4th DCA 2005); Buxton v. Buxton, 963 So.2d 950, 953 (Fla. 2d DCA 2007). We review the trial court’s factual findings to determine whether they are supported by competent, substantial evidence. Buxton, 963 So.2d at 953.

In Buxton, the Second District Court of Appeal discussed the new provision of section 61.14(l)(b) and determined that financial support is but one factor to be considered in concluding whether a “supportive relationship” exists. While consideration of financial support is an important part of that analysis (determining which relationships are equitably analogous to marriage) that factor alone does not define whether a “supportive relationship” exists. Id. at 955.

The former wife in Buxton lived with her paramour for ten years in a house owned by the former wife. 963 So.2d at 955. The paramour paid her rent of $575 per month which was not listed as “rent” on the former wife’s tax returns. Id. at 952. The couple slept in the same bed and shared household chores, maintenance, and items. Id. at 955. The couple, however, did not have joint bank accounts. Id. The [307]*307appellate court concluded that the factors presented in Buxton established that the couple was in a long-term relationship that provided both economic and social support equivalent to that of a marriage. Id. The court therefore determined that a “supportive relationship” as contemplated by section 61.14(l)(b) existed. Id. In reaching its decision, the court relied in part on legislative material that section 61.14(b) is meant to “provide an alternate method to a court to reduce or terminate alimony, without first having to find that there has been a change in financial circumstance, as is the case in current law.” Id. at 951 (citing Sen. Staff Analysis, C.B./S.B. 152 at 12 (February 25, 2005)).

Unlike the Second District Court of Appeal in Buxton which determined that the economic impact on the obligee was only part of the analysis in determining if there is a supportive relationship, the trial court in this matter concluded that section 61.14(l)(b) requires a relationship economically equivalent to a marriage. We adopt the reasoning of the trial court. The statute itself is clear in this regard.

As a matter of law, section 61.14(l)(b) requires the court to determine if an alimony obligee has entered into a relationship that provides the economic support equivalent to a marriage, and if so, the court may reduce or terminate alimony as the equities require. Section 61.14(l)(b) is actually a codification of prior case law which held that, in post dissolution matters, cohabitation can be a basis for reduction or termination of alimony awards. See Zeballos v. Zeballos, 951 So.2d 972 (Fla. 4th DCA 2007); Reno v. Reno, 884 So.2d 462 (Fla. 4th DCA 2004). In the cohabitation cases, courts were required to determine whether and how the new living situation impacted the alimony recipient’s financial condition and the continued need for alimony. Zeballos, 951 So.2d at 974; McBride v. McBride, 352 So.2d 1254 (Fla. 1st DCA 1977). Section 61.14(l)(b)2. now sets forth eleven nonexclusive statutory factors to guide the trial courts in determining when an economic supportive relationship exists between the parties. These factors include but are not limited to the length of cohabitation, and whether they have shown financial interdependence, agreed expressly or impliedly to support one another, actually supported one another, performed services for each other, bought property or assets together, or supported each other’s children. The court may rely on any factor listed, as well as others not listed, either alone or in combination, as the circumstances may suggest to find that their cohabitation is a supportive relationship. § 61.14(l)(b)2., Fla. Stat. (2007). The factors are therefore suggestions or guidelines to assist the court in determining whether the cohabitation is supportive in the same way that modern marriage is supportive.

In its Final Order, the trial court performed a detailed analysis of the eleven statutory factors and the facts of the case that applied to each factor. After weighing the factors in relation to the facts of the case, the trial court found that the former wife and Mr. Stewart were not in a supportive relationship as set forth in the statute. The trial court’s findings were supported by substantial competent evidence.

■ The evidence at trial was largely uncon-tradicted. The former wife and Mr. Stewart have resided together in his home for more than five years. They sleep in the same bedroom; they share cooking and household duties; and they host joint social events. Mr. Stewart pays the monthly mortgage on his home. The former wife’s name is not on the title of Mr. Stewart’s home or on the mortgage. The former wife and Mr. Stewart do not refer to each [308]*308other as husband and wife and they have not expressed any intent to marry. Each purchases groceries and household goods for the house which they freely share. They have never pooled their assets or income. The former wife has a savings account solely in her name. Her name is not on any of Mr. Stewart’s bank accounts and she has no access to such accounts. They do not have and never have had a bank account containing intermingled funds. They have not purchased any property together. They have not expressed any intention to merge their assets or otherwise share any of the property they currently own or possess. The former wife has no credit cards and is not an .

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Linstroth v. Dorgan
2 So. 3d 305 (District Court of Appeal of Florida, 2008)

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Bluebook (online)
2 So. 3d 305, 2008 Fla. App. LEXIS 8434, 2008 WL 2356760, Counsel Stack Legal Research, https://law.counselstack.com/opinion/linstroth-v-dorgan-fladistctapp-2008.