STACY D. JAEGER, APPELLANT,
v.
ROBERT M. JAEGER, APPELLEE
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Stacy Jaeger appeals a final judgment of dissolution of marriage, challenging the trial court's equitable distribution of marital assets. The Fourth District Court of Appeal reverses in part, finding that the trial court's valuations of the former wife's retirement accounts were not supported by competent, substantial evidence and failed to reflect a stipulation by the parties.
The trial court erred in valuing the retirement accounts without competent evidentiary support and in failing to reflect the parties' stipulation regarding the $26,000 marital asset value. The court reversed the equitable distribution as it related to the retirement accounts for recalculation and remanded for further proceedings.
[1] A trial court's determinations within a dissolution judgment are reviewed for abuse of discretion and will be upheld unless not supported by competent evidence.
[2] A final judgment distributing marital assets or liabilities must be supported by factual findings based on competent substantial evidence.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“A final judgment of any distribution of marital assets or liabilities "shall be supported by factual findings .. ,s based on competent substantial evidence .,, [and] include specific written findings of fact as to ... [any] findings necessary to advise the parties or the reviewing court of the trial court's rationale for the distribution”
Establishes the statutory requirement for equitable distribution judgments to be supported by competent, substantial evidence with specific written findings
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Join FLexlaw to unlock all legal intelligenceIn a dissolution of marriage proceeding, the trial court valued the former wife's retirement accounts at $61,312, $68, and $643 respectively. However,…
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Stacy D. Jaeger (“the former wife”) , appeals and Robert J. Jaeger (“the former husband”) cross-appeals a final judgment of dissolution of marriage. We reverse in part, finding merit in the former wife’s argument that the. trial court erred when devising its plan of equitable distribution. The record before us reveals that the trial court’s determinations were not supported by competent, substantial evidence.
“We review the determinations of a trial court within a dissolution judgment for abuse of discretion. The determinations will be upheld unless they are not supported by competent evidence.” Jordan v. Jordan, 127 So.3d 794, 796 (Fla. 4th DCA 2013) (internal citation omitted).
With regard, to equitable distribution, we have previously explained:
A final judgment of any distribution of marital assets or liabilities “shall be supported by factual findings .. ,s based on competent substantial evidence .,, [and] include specific written findings of fact as to ... [any] findings necessary to advise the parties or the reviewing court of the trial court’s rationale for the distribution — ” § 61.075(3)(d), Fla. Stat. (2012). Where certain findings are not supported by competent evidence, reversal of the final judgment is proper. See Konz v. Konz, 63 So.3d 845, 846 (Fla. 4th DCA 2011) (reversing a final judgment for recalculation of the equitable distribution where the evidence at trial did not support the trial court’s findings and where the trial court failed to factor certain marital liabilities). Specific factual findings underlying the court’s determinations are not required to be expressly stated where the record contains competent evidence to support the trial court’s findings. Kelly v. Kelly, 557 So.2d 625, 627 (Fla. 4th DCA 1990).
Id, (alterations in original).
The trial court found that the former wife had retirement accounts worth $61,312, $68, and $643, respectively, but there does not appear to be support for these figures in the record presented to us. Furthermore, it appears that the parties stipulated to a $26,000 marital asset portion of the retirement account that the trial court nonetheless valued as $61,312. Thus, the final judgment should have reflected the value agreed upon by the parties. Cf. Porter v. Porter, 152 So.3d 833, *416835 (Fla. 2d DCA 2014) (“Stipulations regarding equitable distribution that are properly entered into are binding on the court as well as the parties”).
Consequently, we reverse for recalculation of the equitable distribution insofar as it relates to the former wife’s retirement accounts.
We find no merit as to the remaining issues raised in both the appeal and the cross-appeal and therefore affirm without comment.
Affirmed in part, reversed in part, and remanded.
CIKLIN, C.J., TAYLOR and KLINGENSMITH, JJ., concur.
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Authorities Cited
- Kelly v. Kelly, 557 So. 2d 625 (Fla. 4th DCA 1990)
- Jordan v. Jordan, 127 So. 3d 794 (Fla. 4th DCA 2013)
- Konz v. Konz, 63 So. 3d 845 (Fla. 4th DCA 2011)
- Porter v. Porter, 152 So. 3d 833 (Fla. 2d DCA 2014)