In making a division of property and assets, the Court must make specific findings identifying, valuing and distributing the assets and liabilities of the parties. In Patino v. Patino the Fourth District Court of Appeal recently stated: "We again remind trial judges of the importance of making explicit findings as to all statutorily mandated factors for the determination of alimony in final judgments, as well as establishing a value (even if zero or de minimus) for all marital assets and liabilities when devising an equitable distribution scheme.
In a divorce proceeding involving a prevailing party provision in a marital settlement agreement, where claims are separate, the prevailing party on each claim is entitled to an award of fees. Where claims are inextricably intertwined, an award of fees in favor of the prevailing party is appropriate. InSchoenlank v. Schoenlank, the Florida Court of Appeal recently stated:
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
In a divorce action in Florida, private school tuition will be awarded as an incident of child support if the parties have the ability to pay for private school tuition, the expense is in accordance with parties' standard of living, and private school is found to be in children's best interests. In a recent Florida Court of Appeal decision captioned Brennan v. Brennan, the Florida Court of Appeals dealt with this issue.