Alimony Modification - Impact of Inflation in Florida
In order to obtain an upward modification of alimony based upon inflation, the payee must demonstrate how inflation specifically impacts upon the payee's need. "While the trial court was correct that Bedell does allow that the increased cost of living over time can qualify as a 'change in circumstances,' the reduction in the purchasing power of the dollar is insufficient grounds, on its own, to support a modification. See Greene v. Greene, 372 So. 2d 189 (Fla. 3d DCA 1979); Hillier v. Iglesias, 901 So. 2d 947, 948 (Fla. 4th DCA 2005). Rather, 'there must be a showing that the national problem of inflation impacts specifically on the individual claiming inflation as the basis for modification.' Waldman, 520 So. 2d at 89. In Waldman, this Court was faced with facts quite similar to the instant case. An upward modification was reversed expressly because there was 'a marked absence of the required showing of a real change in the circumstances of a party as opposed to an abstract and largely irrelevant change in the economy as a whole.' Id... Furthermore, Wife's reliance on Bedell is misplaced. Although Bedell did consider the increased costs of living, the circumstances in Bedell nowhere resemble the facts of the instant case: '[The former wife] testified that because the cost of living had gone up since the divorce, her standard of living had gone down. Her major appliances, such as the dishwasher, the trash compactor, and the dryer, need to be replaced because the original items are now over fifteen years old. The carpet in the townhouse is worn out and the plumbing is in need of repair. She puts bed sheets over the windows at night because of the absence of drapes. She does not use the air conditioner because she cannot afford the high electric bills. She needs more money for food and clothing. She drives a [nine-year-old] 1982 automobile that keeps breaking down. Bedell, 583 So. 2d at 1008." Silverman v. Silverman
