PILJEVIC
v.
JANKOVIC

Fla. 2d DCA | 2026-05-22
No. 2025-1112
Bauman, J., Northcutt, J., Villanti, J., Black, J.
2026 FL 6105 Florida District Court of Appeal, Second District (2026)

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Holding

A circuit court has jurisdiction to modify a parenting plan and custody/visitation orders without requiring an express reservation of jurisdiction in the original decree.


Headnotes

[1] A circuit court's jurisdiction to modify a parenting plan and custody or visitation orders does not depend upon an express reservation of jurisdiction in the original dec…

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Key Quotes

“court's jurisdiction to modify a dissolution decree as to custody and visitation of minor children does not depend on an express reservation of jurisdiction in the decree”

Citation to Cone v. Cone, 62 So. 2d 907, 908 (Fla. 1953)

Facts & Procedural History

Lidija Piljevic appealed a circuit court decision regarding modification of a parenting plan in a dissolution of marriage case involving minor childre…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF FLORIDA

SECOND DISTRICT

LIDIJA PILJEVIC, Appellant,

V.

GORAN JANKOVIC, Appellee.

No. 2D2025-1112

May 22, 2026

Appeal from the Circuit Court for Hillsborough County; Robert A. Bauman, Judge.

Roland A. Hermida, Tampa, for Appellant.

Thomas A. Burns of Burns, P.A., Tampa; and Nicholas P. McNamara of Creed & Gowdy, P.A., Jacksonville (appeared after briefing), for Appellee.

PER CURIAM.

Affirmed. See Fla. R. App. P. 9.315(a); see also Cone v. Cone, 62 So. 2d 907, 908 (Fla. 1953) (holding that court's jurisdiction to modify a dissolution decree as to custody and visitation of minor children does not depend on an express reservation of jurisdiction in the decree); Bilbo v. Bilbo, 688 So. 2d 1031, 1032 (Fla. 5th DCA 1997) (same); § 61.13(2)(d), Fla. Stat. (2024) ("The circuit court in the county in which either parent

and the child reside or the circuit court in which the original order approving or creating the parenting plan was entered may modify the parenting plan.").

NORTHCUTT, VILLANTI, and BLACK, JJ., Concur.

Opinion subject to revision prior publication.


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