Mani v. Mani

Florida Fourth District Court of Appeal · 2006 · Family Law

927 So. 2d 1087 (2006)

Updated August 1, 2026

Family Lawalimonyfaultforeign judgmentmodificationenforcementFlorida judgmentUIFSA

Facts

A New Jersey final judgment of divorce entered in 2002 required Brenda Mani to pay James Mani $610 per week in alimony, subject to modification under New Jersey law upon James's cohabitation with an unrelated member of the opposite sex. After the judgment, both parties became residents of Palm Beach County, Florida. Brenda filed in Florida a petition for modification and/or enforcement of the New Jersey judgment. Her filing did not seek to establish the New Jersey judgment as a Florida judgment.

Issue

May a Florida court exercise jurisdiction to modify the alimony provisions of a foreign divorce judgment when the party seeking relief has not first established that foreign judgment as a Florida judgment? Does the availability of cumulative remedies outside UIFSA eliminate that requirement?

Rule

A Florida court has jurisdiction to modify the alimony provisions of a foreign judgment only after the foreign judgment has been established as a Florida judgment. Although UIFSA remedies are cumulative and do not eliminate other remedies, that does not dispense with the requirement that the foreign judgment first be established in Florida before modification may be sought.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A Colorado divorce decree requires Elena Morris to pay monthly alimony to Victor Lane. After both move to Tampa, Florida, Elena files in a Florida circuit court a petition to reduce alimony based on Victor's changed financial circumstances, but the petition does not ask the court to establish the Colorado decree as a Florida judgment.

How should the Florida court rule on Elena's request to modify alimony?

Explanation. A Florida court may modify alimony provisions in a foreign judgment only after that foreign judgment has been established as a Florida judgment. The parties' Florida residency does not eliminate that prerequisite. Because Elena sought modification without first establishing the Colorado decree in Florida, dismissal is proper.