Appellate Court Trends in Rehabilitative Alimony: 10 Years Later (Florida‪)‬

Rehabilitative alimony is a tool used by courts to allow a former spouse to "establish the capacity for self-support ... either through the redevelopment of previous skills or provision of the training necessary to develop potential supportive skills." (1) An award of rehabilitative alimony should be based on a consideration of the factors set forth in F.S. [section]61.08. It is clear that some statutory factors carry more weight than others when the issue of rehabilitative alimony is before the court; however, there are factors not mentioned in [section]61.08 that can also influence a court in its rehabilitative alimony decisions. Ten years ago, appellate court trends in both permanent alimony awards and rehabilitative alimony awards were examined. (2) During this time, many cases have been decided which require a second look at the trends. (3) This article will examine decisions on rehabilitative alimony during the past 10 years. (4) This article addresses the cases and trends emerging since 1997 and only addresses initial awards of rehabilitative alimony, not modification proceedings.