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Swain v. Swain

Citations: 783 So. 2d 344; 2001 Fla. App. LEXIS 5961; 2001 WL 434920Docket: No. 1D00-3910

Court: District Court of Appeal of Florida; May 1, 2001; Florida; State Appellate Court

Narrative Opinion Summary

The court affirmed the “Second Amended Order on Motion to Compel and for Contempt” against the former husband for contempt due to (1) his failure to pay "family support" as defined in the marital settlement agreement, along with applicable court charges, and (2) his failure to maintain life insurance as security for this support obligation. However, the court reversed the order's findings of contempt regarding property distribution provisions of the settlement agreement, clarifying that contempt cannot enforce such provisions. Additionally, the court reversed the award of attorney fees to the former wife due to a lack of findings concerning her need for those fees. The decision was affirmed in part and reversed in part, with Judges Webster, Davis, and Benton concurring.

Legal Issues Addressed

Attorney Fees Based on Need

Application: The court reversed the award of attorney fees to the former wife due to the absence of findings concerning her need for those fees.

Reasoning: Additionally, the court reversed the award of attorney fees to the former wife due to a lack of findings concerning her need for those fees.

Contempt for Non-Payment of Family Support

Application: The court found the former husband in contempt for failing to pay 'family support' as required by the marital settlement agreement.

Reasoning: The court affirmed the 'Second Amended Order on Motion to Compel and for Contempt' against the former husband for contempt due to (1) his failure to pay 'family support' as defined in the marital settlement agreement, along with applicable court charges, and (2) his failure to maintain life insurance as security for this support obligation.

Enforcement of Life Insurance as Security for Support

Application: The court held the former husband in contempt for failing to maintain life insurance as security for his support obligation.

Reasoning: The court affirmed the 'Second Amended Order on Motion to Compel and for Contempt' against the former husband for contempt due to...his failure to maintain life insurance as security for this support obligation.

Limitation on Contempt for Property Distribution

Application: The court reversed the contempt findings related to property distribution provisions, asserting that contempt cannot enforce such provisions.

Reasoning: However, the court reversed the order's findings of contempt regarding property distribution provisions of the settlement agreement, clarifying that contempt cannot enforce such provisions.