Amanda Cudworth v. Joseph Trozzo

Summary

The Florida First District Court of Appeal reversed an order requiring Amanda Cudworth to pay unreimbursed expenses, band fees, and Joseph Trozzo's attorney's fees in a child-support enforcement matter. The court held that the trial court improperly relied on unsupported spreadsheet amounts and included expenses incurred before Trozzo sought a child-support order.

Holdings

1. The trial court abused its discretion by granting the motion for enforcement because the documentation failed to support the spreadsheet amounts and many of the claimed expenses were incurred before Trozzo sought a child-support order.
2. The attorney's-fee award to Trozzo was reversed because Trozzo should not have prevailed on the motion for enforcement.

Questions Presented

1. Whether the trial court abused its discretion by granting Trozzo's motion for enforcement based on unsupported spreadsheet amounts and expenses incurred before a child-support order was sought.
2. Whether the award of attorney's fees to Trozzo could stand when he should not have prevailed on the enforcement motion.

Disposition

reversed