STEVEN HEWELL
v.
JOUDELENE HEWELL

Fla. 3d DCA | 2025-08-27
No. 2024-1501
Multack, J., Emas, J., Fernandez, J., Lobree, J.
2025 FL 7380 Florida District Court of Appeal, Third District (2025)

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Holding

A trial court's equitable distribution of marital debts in a dissolution of marriage is reviewed for abuse of discretion, and an appellant's failure to provide a trial transcript and file a motion for rehearing in the trial court precludes meaningful appellate review.

Headnotes

[1] An appellant's failure to provide a trial transcript and failure to file a motion for rehearing in the trial court precludes appellate review of claims requiring review f…

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Key Quotes

“We review an equitable distribution determination for an abuse of discretion.”

Standard of review for equitable distribution in family law cases
Facts & Procedural History

Steven Hewell appealed a final judgment of dissolution of marriage, challenging the trial court's unequal distribution of marital debts and claiming t…

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Topics
Appellate Record Requirements Fundamental Error Doctrine Division Of Marital Property Abuse Of Discretion Standard On Appeal

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Per_curiam
Per Curiam

Third District Court of Appeal State of Florida

Opinion filed August 27, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D24-1501 Lower Tribunal No. 22-23437-FC-04 ________________

Steven Hewell, Appellant,

vs.

Joudelene Hewell, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Spencer Multack, Judge.

Law Office of David Scott, P.A., and David Scott (Fort Lauderdale), for appellant.

Joudelene Hewell, in proper person.

Before EMAS, FERNANDEZ and LOBREE, JJ.

PER CURIAM.

Footnotes
2 Steven Hewell (the “Former Husband”), appeals a final judgment of dissolution of marriage, contending that the trial court erred in unequally distributing the marital debts, finding that there was an agreement by Former Husband to pay them, and failing to value and equally distribute all of his claimed marital debts. “We review an equitable distribution determination for an abuse of discretion.” Michener v. Michener, 403 So. 3d 1040, 1042 (Fla. 3d DCA 2025) (citing Viscito v. Viscito, 214 So. 3d 736, 737 (Fla. 3d DCA 2017)). Following our review, we affirm the final judgment in all respects. “We note, as a threshold matter, that Former Husband has not provided a transcript of the proceedings in the lower court and therefore (absent a supportable claim of fundamental error) Former Husband has failed to provide an adequate record for meaningful review of those claims which we would review for competent substantial evidence or under an abuse of discretion standard.” Magana v. Machado, 406 So. 3d 317, 318 (Fla. 3d DCA 2025). “In addition, and to the extent Former Husband claims the trial court failed to make requisite factual findings in the final judgment, it has not been properly preserved because Former Husband failed to file a motion for rehearing in the trial court.” Id. (quoting Fla. Fam. L. R. P. 12.530(a) (“To preserve for appeal a challenge to the failure of the trial court to make required findings of fact in the final judgment, a party must raise that issue in
3 a motion for rehearing under this rule.”)). Affirmed.

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