Alimony Modification – Change of Financial Circumstances in Florida
Once a substantial change of circumstances is demonstrated, the trial court must utilize the 61.08 factors to determine the appropriate amount of alimony. “Once the former husband met his initial burden of proving that there was a substantial, permanent, and unanticipated change in circumstances, the trial court was required to consider the relevant section 61.08(2) factors to determine the appropriate amount of alimony, if any, that the former husband should still be obligated to pay. See Donoff v. Donoff, 940 So. 2d 1221, 1223 (Fla. 4th DCA 2006) (holding that ‘all applicable section 61.08(2) factors must be considered in modification proceedings under section 61.14.’). Koski v. Koski.