Mullarkey v. Tiraco

CourtDistrict Court of Appeal of Florida
DecidedJuly 25, 2025
Docket2D2024-1612
StatusPublished

This text of Mullarkey v. Tiraco (Mullarkey v. Tiraco) 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
Mullarkey v. Tiraco, (Fla. Ct. App. 2025).

Opinion

DISTRICT COURT OF APPEAL OF FLORIDA SECOND DISTRICT

DEREK J. MULLARKEY,

Appellant,

v.

MELISSA A. TIRACO,

Appellee.

No. 2D2024-1612

July 25, 2025

Appeal from the Circuit Court for Pasco County; Brian Gnage, Judge.

Elizabeth S. Wheeler of Berg & Wheeler, P.A., Valrico, for Appellant.

No appearance for Appellee.

BLACK, Judge. Derek Mullarkey, the father, appeals from the Amended Final Judgment of Paternity, which modified the parties' timesharing plan and child support. We affirm without comment the judgment to the extent it modified the timesharing plan. But for the reasons expressed below, we reverse the judgment to the extent it awarded child support. Melissa Tiraco, the mother, filed her supplemental petition for modification of timesharing and child support on July 28, 2022; the father filed a counterpetition for modification of timesharing and child support on January 20, 2023. A hearing was held on January 31 and February 1, 2024. The Amended Final Judgment of Paternity modifying timesharing and child support was entered on March 18, 2024. With respect to child support, the amended judgment indicates that the previously entered Final Judgment of Paternity directed that the parties shall alternate claiming the child as a dependent for income tax purposes, with the mother claiming the child on even tax years and the father claiming the child on odd tax years. The amended judgment provides that effective March 2023, the cost of the child's healthcare increased from $20 per month to $260 per month. The amended judgment sets forth the parties' gross incomes, finding that the parties had stipulated to using the mother's income as reflected on her 2022 tax return for determining child support for all relevant time periods and not just for the father's child support obligations in 2022. The amended judgment then purports to adopt the child support guidelines worksheets "attached" to it despite that no child support guidelines worksheets were in fact attached. And then in reliance on an "attached spreadsheet with correlating Child Support Guidelines Worksheets," the amended judgment indicates that the father "owes child support arrears of $3,415.22 from August 2022 through and including February 2024." Like the child support guidelines worksheets, the court also failed to attach the spreadsheet to the amended judgment. Moreover, the amended judgment does not set forth the father's monthly child support obligation for any relevant time period dating back to August 2022, shortly after the mother's petition was filed. "Although we review a trial court's award of child support for an abuse of discretion, a trial court's decisions about support must be

2 supported by competent substantial evidence and factual findings sufficient to enable this court to determine how the trial court made the decisions it did." Lennon v. Lennon, 264 So. 3d 1084, 1085 (Fla. 2d DCA 2007) (citing Augoshe v. Lehman, 962 So. 2d 398, 401 (Fla. 2d DCA 2007)). Neither the child support guidelines worksheets nor any other child support document purportedly relied upon by the court was attached to the amended judgment. In his amended motion for rehearing, the father alerted the trial court to this error. See Tinoco v. Lugo, 342 So. 3d 845, 851 (Fla. 2d DCA 2022) (explaining that a court reversibly errs by failing to attach a child support guidelines worksheet to the judgment (citing J.A.D. v. K.M.A., 264 So. 3d 1080, 1083 (Fla. 2d DCA 2019))); see also McGill v. McGill, 355 So. 3d 563, 565 (Fla. 2d DCA 2023); Sadlak v. Trujillo, 336 So. 3d 1275, 1279 (Fla. 3d DCA 2022). The trial court attempted to remedy this error in its order disposing of the father's amended motion for rehearing entered on May 13, 2025. In that order, it directed the parties to rely on "the child support guidelines filed on 6/11/24"—three months after entry of the amended judgment. But merely incorporating the documents into the amended judgment by referencing them in the rehearing order is insufficient. Cf. Picard v. Picard, 353 So. 3d 685, 686 (Fla. 2d DCA 2022) ("[A]lthough the final judgment adopts the mother's parenting plan, it incorporates that plan only by reference to its trial exhibit number and also includes several modifications to that plan's provisions. Thus, as it stands, there is no single document the parties can look to that comprises the entire approved plan. Accordingly, we reverse and remand for the trial court to award the parties shared decision-making authority as to extracurriculars and to approve and attach to the final judgment a copy

3 of a parenting plan consistent with this opinion."). This is particularly so because the amended judgment does not set forth the father's monthly child support obligations for any of the relevant time periods and the child support guidelines worksheets and supporting documents filed on June 11, 2024, are incomplete and lack clarity. Seven documents related to child support were filed on June 11, 2024. These documents, which were prepared by the mother's counsel, are collectively referred to by handwritten notation as Court Exhibit B. The first document, titled Monthly Support with Alternating Exemptions, sets forth three different monthly child support obligations for the "current year": monthly child support if the mother claims the child as a dependent for income tax purposes, monthly child support if the father claims the child as a dependent for income tax purposes, and monthly child support equating to the average of the first two support amounts listed on the document. No further explanation for the monthly child support amounts is provided, including with regard to the applicability of the average child support amount. The next five documents of exhibit B consist of child support guidelines worksheets for various "scenarios": one is identified as "Ongoing Alternating Tax Exemption," which further indicates that it is for "alt/year 1"; one is identified as "2024 Mother Claiming Child"; two are identified as "2023" and set forth two different support obligations; and one is identified as "2022." The mother's gross monthly income on each of the five worksheets is listed as $2,979, which is the gross monthly income reflected on her 2022 income tax return. The seventh and final document of exhibit B includes "arrears" calculations for the following time periods: August 2022 through December 2022, January 2023 through February 2023, March 2023 through December 2023, and January 2024 through February 2024.

4 It is unclear when (or if) the father is obligated to pay the average child support amount set forth on the first document of exhibit B. It is also apparent that one child support guidelines worksheet is missing— the worksheet for ongoing child support for the years when the father claims the child as a dependent. Moreover, the child support guidelines worksheets do not clearly identify which time period and tax exemption scenario they apply to—this seems particularly problematic for the years when more than one child support calculation is required. These shortcomings not only make it difficult for the father to determine his child support obligations for any given time but also hinder our review of the amended judgment. Cf. Tinoco, 342 So. 3d at 851-52 (reversing in part and remanding for the court to explain how it determined the amount of the mother's monthly child support obligation and to attach the child support guidelines worksheet to the judgment); Sadlak, 336 So.

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Mullarkey v. Tiraco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mullarkey-v-tiraco-fladistctapp-2025.