JASON GARMON
v.
MEAGAN GARMON
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An award of attorney's fees in a post-dissolution proceeding must be supported by competent substantial evidence of the obligor's need for the fees, and reversal is required when such evidence is absent from the record.
[1] In a family law proceeding, an award of attorney's fees must be supported by competent substantial evidence of the requesting party's need for such fees, and the absence…
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Join FLexlaw to unlock all legal intelligenceJason Garmon appealed an order awarding attorney's fees to his former wife, Meagan Garmon, in a post-dissolution of marriage proceeding. Former Husban…
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SIXTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
Case No. 6D2024-1564 Lower Tribunal No. 2018-DR-006333
JASON GARMON, Appellant,
V.
MEAGAN GARMON, Appellee.
Appeal from the Circuit Court for Orange County. Elaine A. Barbour, Judge.
May1, 2026
MARLEWSKI, C.A., Associate Judge.
Former Husband, Jason Garmon, appeals an order awarding attorney's fees to his Former Wife, Meagan Garmon, in an underlying post-dissolution of marriage proceeding as well as the order denying his request for a rehearing on the fees motion. Former Husband argued for the first time in his motion for rehearing that Former Wife failed to prove her need for attorney's fees by competent substantial
evidence which should result in the reversal of the court's order granting fees.¹ We agree. Because the record lacks competent substantial evidence to support Former Wife's need for attorney's fees, we reverse the award. See Saporito v. Saporito, 831 So. 2d 697, 701 (Fla. 5th DCA 2002); Rosen v. Rosen, 696 So. 2d 697, 699 (Fla. 1997); Broemer v. Broemer, 109 So. 3d 284, 290 (Fla. 1st DCA 2013); Lau v. Lau, 407 So. 2d 927, 928 (Fla. 3d DCA 1981); Zahringer v. Zahringer, 813 So. 2d 454, 457 (Fla. 4th DCA 2002); Bohner v. Bohner, 997 So. 2d 454, 457 (Fla. 4th DCA 2008); Bauchman v. Bauchman, 253 So. 3d 1143, 1148-49 (Fla. 4th DCA 2018); Graydus v. Graydus, 414 So. 3d 213, 215 (Fla 4th DCA 2025); Carlson v. Carlson, 719 So. 2d 936, 936 (Fla. 4th DCA 1998).
REVERSED.
STARGEL and SMITH, JJ., concur.
Allison M. Perry, of Florida Appeals, P.A., Tampa, for Appellant.
Wade P. Luther, of The Law Office of Wade P. Luther, P.A., Montverde, for Appellee.
NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING
AND DISPOSITION THEREOF IF FILED
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Garmon v. Meagan Garmon (Fla. 6th DCA 2026)
Authorities Cited
- Rosen v. Rosen, 696 So. 2d 697 (Fla. 1997)
- Broemer v. Broemer, 109 So. 3d 284 (Fla. 1st DCA 2013)
- LAU v. LAU, 407 So. 2d 927 (Fla. 3d DCA 1981)
- Bauchman v. Berta Bauchman, 253 So. 3d 1143 (Fla. 4th DCA 2018)
- Carlson v. Andree Carlson, 719 So. 2d 936 (Fla. 4th DCA 1998)
- Bohner v. Bohner, 997 So. 2d 454 (Fla. 4th DCA 2008)
- Garmon v. Meagan Garmon (Fla. 6th DCA 2026)