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Dirienzo-Gluhareff v. Gluhareff

Citations: 865 So. 2d 7; 2003 Fla. App. LEXIS 18818; 2003 WL 22927230Docket: No. 1D03-0111

Court: District Court of Appeal of Florida; December 11, 2003; Florida; State Appellate Court

Narrative Opinion Summary

The former wife appeals a post-final judgment order that denied her motion to enforce temporary financial support previously granted by the trial court. The court reiterates that provisional or interlocutory proceedings merge into the final decree, thereby nullifying prior orders unless specifically preserved in the final judgment. The appellant waived this issue during trial. Citing case law, the court explains that a final decree dismissing a divorce suit releases the former husband from obligations to pay any temporary alimony arrearages if the final order does not state otherwise. Additionally, interlocutory orders, such as one requiring the former husband to pay medical bills, do not survive the final dissolution judgment. Therefore, since the final judgment did not address any arrearages in temporary support, the former wife cannot enforce prior temporary orders. The judgment is affirmed, with concurrence from Justices Polston and Hawkes.

Legal Issues Addressed

Final Decree and Temporary Alimony Arrearages

Application: The court explained that a final decree dismissing a divorce suit releases the former husband from obligations to pay temporary alimony arrearages unless the final order states otherwise.

Reasoning: A final decree dismissing a divorce suit releases the former husband from obligations to pay any temporary alimony arrearages if the final order does not state otherwise.

Merger of Interlocutory Orders into Final Judgment

Application: The court held that interlocutory proceedings, such as temporary financial support, merge into the final judgment and are nullified unless specifically preserved.

Reasoning: The court reiterates that provisional or interlocutory proceedings merge into the final decree, thereby nullifying prior orders unless specifically preserved in the final judgment.

Non-Survival of Interlocutory Orders Post-Judgment

Application: The court clarified that interlocutory orders, like those requiring payment of medical bills, do not survive after a final dissolution judgment if not addressed in the final judgment.

Reasoning: Additionally, interlocutory orders, such as one requiring the former husband to pay medical bills, do not survive the final dissolution judgment.

Waiver of Issues During Trial

Application: The appellant waived the issue of enforcing temporary financial support during the trial, impacting her ability to contest it post-judgment.

Reasoning: The appellant waived this issue during trial.