Amal Crane v. Matthew Harrison Crane

Summary

The Third District Court of Appeal of Florida reviewed an attorney’s fee award of $95,271.55 entered against a former wife following a contempt finding in a post-dissolution proceeding. The court held that the order was facially deficient because it did not determine the former husband’s need or the former wife’s present ability to pay, and it reversed and remanded solely for that determination.

Holdings

1. An order awarding attorney's fees in a post-dissolution contempt proceeding is facially deficient when it fails to reflect whether the recipient spouse has a need for the fees and whether the other spouse has the present ability to pay them.

Questions Presented

1. Whether the final order awarding attorney's fees after a contempt finding was facially deficient because it failed to determine the former husband's need and the former wife's present ability to pay.
2. Whether the other issues raised by the former wife warranted appellate relief.

Disposition

reversed_and_remanded