Jericka v. Jericka, 198 So. 3d 661

Donald and Linda Jericka were married ~36 years; Linda filed for dissolution in March 2013.
Donald owned and managed an electrical business and filed five financial affidavits during the proceedings showing progressively lower business income.
At final hearing, trial court awarded Linda $2,000/month permanent periodic alimony and found Donald less credible, attributing his income reductions to business management aimed at affecting alimony.
The final judgment largely tracked statutory language and did not otherwise set out detailed factual findings on need and ability to pay.
The appellate record contains no transcript or statement of the evidence as required by Fla. R. App. P. 9.200(b)(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court made required factual findings for alimony under §61.08	Linda contended the court properly awarded permanent periodic alimony based on credibility and evidence	Donald argued the judgment lacked the specific factual findings of need and ability to pay required by statute	Court noted the judgment lacked required factual findings but affirmed because no transcript/statement of evidence was provided, preventing review
Whether absence of transcript prevents appellate review	N/A (issue arises from procedural default)	Donald argued error in findings; asked for reversal	Court held failure to supply transcript or statement under rule 9.200(b)(4) precludes meaningful review and requires affirmation
Whether error was apparent on face of judgment so reversal could occur without transcript	N/A	Donald implied errors were reversible despite missing transcript	Court explained reversal without transcript is only possible when error is apparent on face; here harmless-error review required and transcript absence frustrated that review, so affirmed
Credibility finding effect on review	Court used credibility concerns to support award	Donald contested credibility finding and its sufficiency absent other findings	Court observed trial court discounted Donald due to affidavit amendments but still could not be reviewed without transcript, so outcome affirmed

Crick v. Crick, 78 So. 3d 696 (Fla. 2d DCA) (trial courts must make factual determinations on need and ability to pay alimony)
Farley v. Farley, 800 So. 2d 710 (Fla. 2d DCA) (failure to make required findings on alimony is reversible error)
Melo v. Melo, 864 So. 2d 1268 (Fla. 3d DCA) (judgment that merely tracks statutory language is insufficient)
Klette v. Klette, 785 So. 2d 562 (Fla. 1st DCA) (absence of transcript can preclude appellate review and requires affirmation)
Esaw v. Esaw, 965 So. 2d 1261 (Fla. 2d DCA) (absence of transcript is the primary impediment to meaningful review of findings)
Hoirup v. Hoirup, 862 So. 2d 780 (Fla. 2d DCA) (recognizes limited circumstances where error apparent on face permits reversal without transcript)