BARBARA J. KAUFMAN, APPELLANT,
v.
JAMES M. KAUFMAN, APPELLEE
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Florida appellate court reversed child support awards as inadequate to cover children's documented expenses and remanded for recalculation; also reversed trial court's failure to reserve jurisdiction for future alimony.
Child support awards must reflect all documented expenses of minor children, including private school and summer camps, consistent with their customary standard of living, and trial courts must reserve jurisdiction to award alimony in the future.
[1] Child support awards must be calculated to cover all documented expenses of minor children, including private education and extracurricular activities, consistent with th…
[2] Trial courts must reserve jurisdiction to award alimony in the future even when not awarding alimony at the time of dissolution.
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Join FLexlaw to unlock all legal intelligenceThe parties had three minor children whose undisputed annual expenses substantially exceeded the child support awards made by the trial court, includi…
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PER CURIAM.
Because the record reflects that the undisputed annual expenses of the parties’ three minor children are substantially in excess of the child support awards made by the trial court, we reverse that portion of the amended final decree of dissolution and remand the cause to the trial court with directions to increase the child support awards so that they reflect all expenses of the children — including private schools and summer camps — in accordance with their customary standard of living.
Additionally, the judgment is to be amended to make clear that the obligation to make these child support payments is to be Mr. Kaufman’s, except that his obligation may be satisfied through the equal use of the named custodial accounts to the extent there are sufficient funds therein.
Finally, being of the view that the trial court abused its discretion in failing to reserve jurisdiction to award alimony in the future, we direct that the amended decree be modified accordingly. In all other respects the amended decree is affirmed. The final judgment awarding attorneys’ fees and the order taxing costs and suit money are likewise affirmed.
Amended final decree of dissolution affirmed in part, reversed in part, and remanded with directions. Final judgment awarding attorneys’ fees and order taxing costs and suit money affirmed.
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Matthews v. Matthews, 677 So. 2d 323 (Fla. 1st DCA 1996)…children had attended a private school during the parties' marriage and guardian ad litem recommended that children continue to attend private school in order to minimize disruption of their lives caused by parties' separation); Kaufman v. Kaufman, 491 So. 2d 584 (Fla. 3d DCA 1986) (private school tuition payable in accordance with the children’s customary standard of living); Ault v. Ault, 431 So. 2d 302 (Fla. 2d DCA 1983) (private school expenses payable where the noncustodial parent was a practicing attor…
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Luskin v. Luskin, 492 So. 2d 783 (Fla. 4th DCA 1986)…ility to pay private school tuition and summer camp costs, and these expenses are in accordance with the family’s customary standard of living and are in the children’s best interests, they may properly be awarded as support. See Kaufman v. Kaufman, 491 So. 2d 584 (Fla. 3d DCA 1986); Ault v. Ault, 431 So. 2d 302 (Fla. 2d DCA 1983); Hendry v. Hendry, 340 So. 2d 942 (Fla. 4th DCA 1976). Accordingly, we reverse the trial court’s order denying the wife’s motion to compel and remand for reconsideration of this ma…
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Caryn Heidi Forrest v. Ami RON, 821 So. 2d 1163 (Fla. 3d DCA 2002)…of living, see Bell v. Bell, 811 So. 2d 833 (Fla. 2d DCA 2002); Thomas v. Thomas, 776 So. 2d 1092 (Fla. 5th DCA 2001); Crowley v. Crowley, 672 So. 2d 597 (Fla. 1st DCA 1996); Luskin v. Luskin, 492 So. 2d 783 (Fla. 4th DCA 1986); Kaufman v. Kaufman, 491 So. 2d 584 (Fla. 3d DCA 1986), or if the child has a special need that cannot be met by public schools. See Musser v. Watkins, 752 So. 2d 141 (Fla. 2d DCA 2000); Matthews v. Matthews, 677 So. 2d 323, 327 n. 3 (Fla. 1st DCA 1996); Stefanowitz v. Stefanowitz, 58…
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