Fort Lauderdale Divorce Lawyer Blog
In Florida dissolution proceedings involving minor children, accurate and internally consistent child support calculations are essential. The Florida Child Support Guidelines, codified in a section of the Florida Statutes, mandate a structured approach based on each party’s income and time-sharing responsibilities. If a court fails to comply with such guidelines when issuing a support order, there may be grounds for seeking review, as demonstrated in a recent Florida ruling. If you have questions about your rights or obligations with regard to child support, you should consult a Miami family law attorney as soon as possible.
History of the Case
It is reported that the parties participated in a four-day bench trial concerning the dissolution of their marriage and the establishment of child support obligations for their two minor children. The trial court’s final judgment dissolved the marriage, incorporated the parties’ marital settlement agreement, and adopted a parenting plan. As part of the judgment, the trial court ordered the father to pay the mother approximately $400.00 per month in child support until April 1, 2027, at which point the obligation would be reduced to approximately $150.00 per month for the support of one child.
It is alleged that the trial court attached a Child Support Guidelines worksheet to the judgment as required by Florida law. However, the figures in the attached worksheet conflicted with the child support amounts detailed in the final order. Specifically, it is reported that the worksheet table listed the father’s monthly obligation as approximately $150.00 for two children until April 1, 2027, after which it increased to approximately $400.00 for one child until March 30, 2033. This directly contradicted the amounts stated in the final judgment, effectively inverting the payment schedule.
It is further reported that the father appealed the final judgment, raising several issues regarding child support. However, he did not include trial transcripts in the appellate record.
Challenging Child Support Orders
On review, the court acknowledged the discrepancy between the numerical amounts listed in the final judgment and those in the attached guidelines worksheet. The court held that, even in the absence of a trial transcript, an internal inconsistency apparent on the face of the judgment warranted appellate intervention.
The court emphasized that, while trial courts have broad discretion in determining child support, this discretion must be exercised within the framework of Florida’s statutory guidelines and procedural rules. Florida law dictates that the absence of a transcript typically precludes appellate review unless the judgment contains facial inconsistencies or errors. Here, the court relied on A.A. v. D.W., 326 So. 3d 1186 (Fla. 2d DCA 2021), where an internally contradictory judgment was reversed notwithstanding the absence of a record, because the court’s written findings conflicted with an attached parenting plan.
Accordingly, the court reversed the portion of the final judgment addressing child support and remanded for the trial court to resolve the discrepancy. As to all other issues, including any discretionary rulings based on credibility or factual determinations, the court affirmed due to the lack of a sufficient record to assess the father’s arguments.
Consult a Seasoned Miami Divorce Attorney
In Florida family law, clarity and consistency in final judgments are essential to enforceability and fairness. When orders conflict with supporting documentation, confusion and costly appeals may follow. If you are pursuing or defending against a child support determination, The Law Offices of Sandy T. Fox, P.A., can help you avoid errors that undermine finality. Our experienced Miami family law attorneys serve clients throughout South Florida and are committed to accurate and effective representation. Call us today at 800-596-0579 or contact us online to schedule a confidential consultation.