Addie vs. Coale

Addie vs. Coale has a history in the 4th district. When it was first appealed, it was remanded for reconsideration of the alimony and child support aspects of the final judgment. On remand, the successor trial judge entered an alimony and child support award, but it was deficient in that findings were not made on all of the factors, and the trial court erroneously believed that because of the specific remand it could not consider what had happened financially since the original judgment was entered. The appellate court clarified that the trial judge must consider all of the factors, and it can consider what had happened financially since the original trial because need and ability to pay are both based upon changing circumstances.

Addie v Coale