Automatic changes in alimony are disfavored, however, they may be appropriate upon specifically articulated changes in circumstances. In Voda v. Voda, the Florida Court of Appeal recently stated: “Karen Voda (Former Wife) filed for dissolution of marriage from John Voda (Former Husband) in 2009; the trial court equitably distributed the assets and awarded Former Wife permanent, periodic alimony
…for five years and $1 monthly nominal (support) thereafter. Former Husband challenges the…award on appeal; Former Wife challenges the equitable distribution scheme and a few other points on cross-appeal. Because the trial court erred by failing to determine Former Husband’s ability to pay…we reverse as to that issue only and note a ministerial detail to be considered on remand. The cross-appeal is affirmed without comment…The Former Wife requested various types of (support) including a lump-sum award of the marital property because of her greater need. The trial court declined to award property as lump-sum (support), but did award permanent, periodic alimony…for five years and nominal $1 monthly thereafter to Former Wife particularly in light of her increased insurance needs…Although not an issue in this appeal, we note that ‘automatic changes in alimony payments based upon the occurrence of future events are generally disfavored’ though they ‘may be appropriate when they are ‘carefully conditioned upon specifically articulated changes in circumstances….‘” Walker v. WaIker, 818 So.2d 711, 713 (Fla. 2d DCA 2002) (quoting Kangas v. Kangas, 420So.2d 115,116(Fla. 2d DCA 1982)).”
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