Sonya Witt-Bahls v. Dennis Bahls, 193 So. 3d 35

Husband worked for Kiewit (large, privately held multinational) for 12 years, held a middle-management position and was demoted and later terminated during the marriage.
Husband purchased substantial Kiewit stock before marriage using a bank loan; only interest payments were made and principal was not reduced; stock was later liquidated for more than the loan balance.
Trial court found the stock appreciation passive and nonmarital and therefore not subject to equitable distribution.
Trial court heard extensive evidence about the parents’ fitness; concluded unsupervised timesharing with the mother would be against the child’s best interest and imposed supervised-only contact without specifying steps to remove the restriction.
Mother appealed the distribution ruling and the supervised-timesharing order; the Fourth District affirmed on most issues but reversed limitedly for failure to specify steps to reestablish unsupervised contact.

Issue	Plaintiff's Argument (Witt‑Bahls)	Defendant's Argument (Bahls)	Held
Whether appreciation of premarital Kiewit stock is marital	Appreciation resulted from husband’s employment so the appreciation is marital and divisible	Appreciation was passive; husband was not in significant management role so appreciation is nonmarital	Appreciation is nonmarital; stock appreciation was passive and not subject to equitable distribution
Whether trial court abused discretion by failing to specify steps to restore unsupervised timesharing	Court must provide concrete steps/benchmarks so parent knows how to regain unsupervised time	Court’s general direction and invitation to return when parties/healthcare providers agree was adequate	Trial court abused discretion by not setting specific requirements; remanded to set concrete steps/timeframes

Preudhomme v. Bailey, 82 So. 3d 138 (Fla. 4th DCA 2012) (asset classification reviewed de novo)
Pagano v. Pagano, 665 So. 2d 370 (Fla. 4th DCA 1996) (stock appreciation attributable to active role in family business may be marital)
Oxley v. Oxley, 695 So. 2d 364 (Fla. 4th DCA 1997) (distinguishing passive appreciation from marital enhancement)
Robbie v. Robbie, 654 So. 2d 616 (Fla. 4th DCA 1995) (appreciation of stock tied to spouse’s significant managerial role treated as marital)
Minton v. Minton, 698 So. 2d 936 (Fla. 4th DCA 1997) (stock appreciation marital where spouse held high managerial authority)
Ross v. Botha, 867 So. 2d 567 (Fla. 4th DCA 2004) (trial court must set specific requirements to alleviate timesharing restrictions)
Grigsby v. Grigsby, 39 So. 3d 453 (Fla. 2d DCA 2010) (parent must be given the "key"—specific steps—to reconnect with children)
Davis v. Lopez‑Davis, 162 So. 3d 19 (Fla. 4th DCA 2014) (citing Grigsby; judgment deficient if steps to reestablish timesharing are not specified)
Hunter v. Hunter, 540 So. 2d 235 (Fla. 3d DCA 1989) (same principle regarding timesharing restrictions)
Canakaris v. Canakaris, 382 So. 2d 1197 (Fla. 1980) (standards for abuse of discretion)
Kaaa v. Kaaa, 58 So. 3d 867 (Fla. 2010) (addressing treatment of loan principal and interest in valuation contexts)