Third District Court Reverses Alimony Modification

The Third District Court of Appeal reversed today in Murphy v. Murphy, a case in which the lower court granted a downward modification of alimony based on its finding of a supportive relationship at the same time the court found that the Appellant received no financial support whatsoever from that relationship.  The Third District rejected the ruling on the basis that Florida Statute 61.14(b) and other authority make clear that some form of economic support must be received to support a modification.  The Court further clarified that, despite the varying definitions of the word “support” in regular usage, a “supportive relationship” necessarily involves an alimony recipients receipt of monies from that source as well.