Fazzaro v. Fazzaro, 110 So. 3d 49

Married in 1999 and have one minor child.
Final judgment awarded shared parental responsibility but gave Ms. Fazzaro final decision-making authority if the parties could not agree.
Parenting plan granted Ms. Fazzaro ultimate authority over Education/Academic decisions and Non-emergency health care.
Florida statute §61.13(2)(c)(2) favors shared parental responsibility, with possible sole authority over specific areas.
Trial court failed to make explicit factor findings and provided no clear logic for one-parent control; evidence did not show need for sole authority in education or nonemergency health care.
Relocation decision to Texas was affirmed; issue concerning temporary alimony was moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ultimate authority to one parent abuse of discretion	Fazzaro argues for shared responsibility, no single authority.	Fazzaro contends some necessity for final authority.	Reversed the grant of ultimate authority.
Authority over education and nonemergency health care justified	Fazzaro asserts not justified to assign sole control.	Fazzaro asserts authority necessary for these areas.	Reversed the education and nonemergency health care provisions.
Lack of required findings on parental responsibility factors	Fazzaro argues there were no proper factor findings.	Fazzaro argues findings were unnecessary.	Reversed due to absence of proper findings and rationale.

Kuharcik v. Kuharcik, 629 So.2d 224 (Fla. 4th DCA 1993) (reversing mother’s ultimate authority and remanding for delineation of specific authority)
A.L.G. v. J.F.D., 85 So.3d 527 (Fla. 2d DCA 2012) (abuse of discretion standard for custody decisions)
Schneider v. Schneider, 864 So.2d 1193 (Fla. 4th DCA 2004) (hostility between parents not alone dispositive)
Canakaris v. Canakaris, 382 So.2d 1197 (Fla.1980) (abuse of discretion standard; guidelines for evaluation)
Bader v. Bader, 639 So.2d 122 (Fla. 2d DCA 1994) (need for specific findings when establishing parental responsibilities)