Posted On: January 31, 2009

I’ve Lost My Job, The Economy is Horrible, Do I Still Need to Pay Alimony to My Ex?

The economy is bad, the employment rate is plunging, and life just doesn’t seem to be getting any easier. An important issue that many recently unemployed white-collar workers may be facing is whether their current alimony payments to their ex-spouse should remain at the same rate. It’s not hard to imagine a scenario that when Husband and Wife were going through a divorce 3 years ago, Husband worked a management level position at a Finance Corporation in Boca Raton, was getting paid a high salary, and his wife was a stay-at-home mother living at the couple’s home in Fort Lauderdale. When Husband and Wife got divorced, Husband was required to pay alimony to Wife, the terms of which were set in accordance with Husband’s high-paying job at the time. But, now it’s 2009, Husband has lost his job, and because of the downturn in the economy, Husband has no employment prospects in the near future. Husband’s savings are declining at a rapid pace, and he can no longer pay the required alimony payments dictated by a three-year-old divorce settlement agreement.

At the time of divorce, the parties’ needs and abilities to pay are settled by a final judgment awarding alimony. However, a final judgment requiring one party to pay the other alimony may be modified or even temporarily suspended. A party may petition the court to modify alimony, but the moving party must show: (1) a substantial change in circumstances has occurred; (2) that the change in circumstances was not contemplated at the time the divorce settlement was reached; and (3) that the change in circumstances is sufficient, material, involuntary, and permanent in nature. In the fact situation described above, the first two requirements are easily met. Husband has lost his job and cannot find a new job, severely reducing his income – no doubt a substantial change. Furthermore, this change could not have been contemplated 3 years ago when Husband was gainfully employed. The real issue in this situation is whether the change in Husband’s circumstances is permanent enough to warrant a reduction, or at least a temporary reduction or suspension, in his alimony payments to his Wife.

Florida law dictates that a showing of substantial change in circumstances is sufficiently “permanent” when the conditions exist for one year or more. However, an important caveat to this general rule is that not all circumstances must adhere to this standard. In fact, there may be fact situations where the permanence of a situation can be proved right away. Could this just be one of those situations that warrant such treatment? A recent article made an interesting argument that with the downsize of the financial sector, it should be easier for unemployed and underemployed professionals to minimize alimony by arguing “their plunge in fortunes isn’t short-lived” and is most likely permanent in nature. That argument aside, in Florida, a temporary modification in alimony is appropriate where the court determines that Husband has suffered a reduction in income without deliberately seeking to avoid paying alimony and is acting in good faith to return his income to its previous level. In fact, when such a situation arises, the Husband’s alimony obligation should be reduced to be more commensurate with his current ability to pay. Also, a court may even suspend payments temporarily if such inability to pay arises. It’s important that in these uncertain times to take advantage of what Florida courts allow.

If you are currently paying alimony payments to your ex-spouse and have lost your job and do not see any hopeful employment prospects in the future, the best advice would be to consult a lawyer concerning your ability to either temporarily or permanently reduce your alimony payments.

Posted On: January 21, 2009

Modifying Alimony Agreements – A Palm Beach Gardens, Florida Bizarre Reading of a Modification Clause

In the state of Florida, including the city of Palm Beach Gardens, an alimony agreement reached as part of a divorce settlement acts as a binding contract on the parties involved. An example of such an agreement would be where one spouse agrees to pay the other spouse $2000 a month in alimony for a certain period of time or until that spouse remarries. When parties enter into such an agreement in connection with a divorce, and the circumstances or the financial ability of either party substantially changes, either party may apply to the circuit court for an order to increase or decrease the alimony amount. However, it is well-established that the statutory right to petition for modification of an alimony award may be intentionally or impliedly waived. This waiver to modify alimony terms may be expressed within the agreement or through interpretation of the agreement as a whole.

Last month, the Palm Beach Post included an editorial “Divorced from reality,” discussing a 4th District Court of Appeal case, Craissati v. Craissati, that applied modification and waiver of alimony law to reach an absurd result. In 2001, a husband and wife divorced with a final judgment for dissolution of marriage, which incorporated the parties’ marital settlement agreement, including a provision for alimony. Pursuant to the terms of that agreement, the former husband agreed to provide 8 years of alimony in the amount of $2000 a month to his former wife. However, the agreement contained a clause providing for termination of alimony. That clause explicitly stated that any “future alimony payments owed to the Wife ends upon the death of either party, remarriage, or cohabitation with another person other than the parties’ child. ‘Cohabitation’ shall be defined as the Wife living with another person (not including the parties’ child) for a period of 3 (three) consecutive months or more.” The agreement then contained a waiver clause, stating that the terms and nature of alimony could not be modified by either party for any other reason except for the husband’s proven decline in financial condition.

In 2005, the former wife was sentenced to 9 years in prison in connection with criminal convictions for driving under the influence, leaving the scene of an accident and causing serious bodily injury. Thereafter, the former husband filed a petition for modification of alimony. Because the husband could only modify the terms of the agreement under the conditions previously mentioned, his lawyers got creative – and the 4th DCA bought their argument. To get around his agreement’s modification waiver, the former husband argued that the incarcerated wife was cohabitating with her cell mate, and during an evidentiary hearing, the wife stipulated that her cell lifestyle met the alimony agreement’s definition of “cohabitation.” The court agreed with the husband’s argument, and the wife’s alimony was cut off! To read the full case, click here.

What should we take away from this absurd result? Perhaps this case stresses the importance of proper drafting of settlement agreements. If you are going through a divorce, consult an attorney for advice about your settlement agreement.

Posted On: January 7, 2009

Child Support – Who Is Paying for My Child’s College Education?

In these uncertain financial times, the specific terms of a child support agreement within a divorce settlement has become even more important than before. One important factor that parties to a divorce may forget, or may not even think to mention, is payment of their child’s college education. In today’s society, undoubtedly driven by education, a college degree has become the pinnacle of entering Florida’s workforce. Recognizing this, many Floridians decide to help pay for their child’s college education upon graduation from high school. However, when a child’s parents are going through a divorce, and child support obligations are being mentioned by both parties, the question of who must pay for a child’s college education is a matter that should be discussed.

Florida statute mandates that a parent is not legally obligated to support his or her child beyond the age of 18, the age of majority, unless the parent agrees to get around this by signing a binding contract or unless some type of statutory exception applies pertaining to a child’s disability or dependency. With the statutory exceptions, a parent may be required to support a dependent child where: (1) dependency is caused by mental or physical incapacity which occurred before the child reached 18; or (2) the child is “dependent in fact,” meaning that he or she is between the ages of 18 and 19, is currently enrolled in high school, and has a reasonable expectation of graduating before 19. Absent a court order, binding contract, or these two statutory exceptions, the obligation to pay the current child support for a child, including payment for secondary education upon completion of high school, is terminated when the child reaches the age of 18.

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Where exactly does that leave a child of parents going through a divorce that just graduated high school, is 18 years of age, and needs financial support from his parents to attend college in his hometown of Fort Lauderdale, Florida? As stated previously, if a child is no longer “dependent” upon his or her parents, either through age or disability, a parent simply has no absolute duty to provide a child financial support, which unfortunately includes paying or helping to pay for an adult child’s college education. If you are a parent going through a divorce, and are worried about paying for your child’s college education, the best thing to do is to bring up the topic in preliminary discussions between the parties. Although a parent is under no legal obligation to provide support a child over the age of 18, the age of most college students, it is important to note that the support agreement may require a parent to pay support beyond the age of 18. Through contract, one parent may require the other parent to pay and be solely responsible for a child’s college education, thereby obligating that parent to pay reasonable costs associated with it. The exact terms should be stipulated in the contract. If the support contract fails to address this matter explicitly, the court is unlikely to honor the request. Getting around this failure would require one parent to make a motion to the court requesting a change to the terms of the support obligations within the divorce settlement agreement to include a provision for college education support. However, the decision to grant this motion is within the court’s discretion. The wiser route would be to include such a provision within the original divorce settlement agreement binding both parties to its contractual terms.

If you are going through a divorce and are concerned about your child’s financial support for his or her college education, please consult an attorney for more information.