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Adelman v. Adelman

Citations: 543 So. 2d 237; 14 Fla. L. Weekly 677; 1989 Fla. App. LEXIS 1309; 1989 WL 21417Docket: Nos. 87-2245, 87-1430

Court: District Court of Appeal of Florida; March 13, 1989; Florida; State Appellate Court

Narrative Opinion Summary

In the appellate review of a marriage dissolution judgment, the court affirmed the dissolution but reversed the trial court's property awards due to insufficient evidence. The trial court had conducted private discussions with counsel and engaged in informal hearings on asset distribution without formal testimony. Mrs. Adelman objected to the announced asset distribution and monetary awards, citing a lack of factual support and absence of a property settlement agreement. The appellate court found that the trial court erred in its understanding that it could not combine awards of the marital home and permanent periodic alimony. Furthermore, the appellate court reversed the award of attorney's fees to Mr. Adelman's counsel due to the absence of a stipulation limiting such fees, directing adherence to established guidelines on remand. The case was remanded for an evidentiary hearing to permit the presentation of testimony and evidence by both parties. The decision resulted in a partial reversal and remand for further proceedings consistent with relevant case law.

Legal Issues Addressed

Attorney’s Fees in Marital Dissolution

Application: The appellate court reversed the trial court's award of attorney's fees due to the absence of a stipulation limiting such fees, and instructed adherence to guidelines on remand.

Reasoning: The appellate court agrees with Mrs. Adelman that there was no stipulation limiting the husband's attorney's fees, leading to the reversal of that award.

Combining Marital Home and Permanent Periodic Alimony Awards

Application: The trial court erred in stating it could not combine awards of the marital home and permanent periodic alimony if justified, which the appellate court clarified.

Reasoning: The trial court had incorrectly stated it could not award Mrs. Adelman the marital home or permanent periodic alimony, although such awards can be combined if justified.

Property Awards in Dissolution of Marriage

Application: The appellate court reversed the trial court's property awards due to a lack of sufficient evidence supporting the decisions.

Reasoning: The dissolution is affirmed; however, the property awards are reversed due to insufficient evidence supporting the trial court’s decisions.

Requirement for Evidentiary Hearing

Application: The appellate court remanded the case for an evidentiary hearing to allow both parties to present testimony and evidence regarding asset distribution.

Reasoning: Citing precedents, the court found a lack of factual basis for the awards and remanded for an evidentiary hearing, allowing both parties to present testimony and evidence.