Loftis v. Loftis, 208 So. 3d 824

Dawnmarie Loftis (Former Wife) and Daniel Loftis (Former Husband) divorced; the trial court entered a final judgment establishing a parenting plan and child support allocation.
After the final hearing but before entry of final judgment, Former Wife filed a motion to reopen to admit evidence of her employment termination (termination notice and affidavit), arguing her unemployment would materially affect child support calculations.
Former Husband opposed reopening, asserting the new evidence was not an inadvertent omission, would require additional discovery (e.g., whether unemployment was voluntary, whether income should be imputed, future employability), and would prejudice him by delaying final resolution.
The trial court held two hearings on the motion and denied it; the final judgment used Former Wife’s pre-termination salary to calculate support and awarded two-thirds of overnights to Former Husband.
The Fifth District affirmed, reviewing denial of a motion to reopen for abuse of discretion and concluding the trial court did not abuse its discretion in denying the motion, noting reopening would effectively restart the case and prejudice the opposing party.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying Former Wife’s motion to reopen to admit evidence of her job termination	Reopening was timely and necessary because her income materially changed after the hearing and before final judgment; the termination notice and affidavit warranted reconsideration of child support	Reopening would introduce a new issue (not an inadvertent omission), require substantial additional discovery and delay, and prejudice Former Husband; any change can be addressed by modification under §61.14	Denial affirmed. Court found reopening would unduly prejudice Former Husband and essentially require restarting the case; no abuse of discretion.

Grider-Garcia v. State Farm Mut. Auto., 73 So. 3d 847 (Fla. 5th DCA 2011) (standards and factors for reopening evidence and abuse-of-discretion review)
Amador v. Amador, 796 So. 2d 1212 (Fla. 3d DCA 2001) (reopening allowed for inadvertently omitted evidence)
Robinson v. Weiland, 936 So. 2d 777 (Fla. 5th DCA 2006) (reopening requires weighing prejudice and best interests of justice)
Register v. State, 718 So. 2d 350 (Fla. 5th DCA 1998) (factors for evaluating requests to reopen evidence)
Silber v. Cn’R Indus. of Jacksonville, Inc., 526 So. 2d 974 (Fla. 1st DCA 1988) (distinguishing inadvertent omission cases from requests that seek to change evidence/facts)
Byrne v. Byrne, 128 So. 3d 2 (Fla. 3d DCA 2012) (distinguished because defendant did not oppose reopening and prejudice was not discussed)
Hernandez v. Cacciamani Dev. Co., 698 So. 2d 927 (Fla. 3d DCA 1997) (reopening to admit originally omitted evidence)