Fourth District Reverses Denial of Alimony Modification

The Fourth District Court of Appeal reversed today in Koski v. Koski, a case in which the lower tribunal denied the Former Husband’s petition seeking modification of his alimony obligation.  While the lower court found a substantial increase in the Former Wife’s income, no findings were made as to whether the increase was contemplated, or whether it was permanent.  The Fourth District noted that the change appeared to be both permanent in nature and outside the circumstances contemplated at time of Final Judgment.  Given this, the Court found error in the lack of findings made by the lower court showing that a review of the statutory factors did not support a modification, and remand was required for these findings to be made.