Kathleen Pierre Bryan v. Ricardo Bryan

No. 4D2024-3319 (Fla. 4th DCA Dec. 10, 2025) · District Court of Appeal of the State of Florida, Fourth District · December 10, 2025 · No. 4D2024-3319

Summary

The Florida Fourth District Court of Appeal reviewed a final judgment of dissolution of marriage. It reversed and remanded because the judgment lacked required findings concerning timesharing, parental communication, and jurisdiction under sections 61.13(2)(b) and 61.046(14)(b), while affirming the judgment in all other respects.

Holdings

  1. A final judgment of dissolution must contain the required findings on all applicable elements of section 61.13(2)(b), including specific timesharing terms and the methods the parents will use to communicate with the children.
  2. A parenting plan must include the jurisdictional findings required by section 61.046(14)(b), Florida Statutes (2024).
  3. The former wife's remaining arguments did not warrant relief and were affirmed without further discussion.

Questions Presented

  1. Whether the final judgment of dissolution contained the findings required by section 61.13(2)(b), Florida Statutes (2024).
  2. Whether the parenting plan contained the jurisdictional findings required by section 61.046(14)(b), Florida Statutes (2024).
  3. Whether the former wife's remaining arguments warranted appellate relief.

Disposition

reversed_and_remanded

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