Tyler Frazier v. Katherine Dodd
5D2022-2478
Fla. Dist. Ct. App.Mar 21, 2025Background
- Tyler Frazier (“Husband”) and Katherine Dodd (“Wife”) were married in 2010; Husband filed for divorce in 2019.
- The parties reached agreement on many divorce issues, but unresolved matters (marital home valuation/distribution, alimony, mortgage payment credits) went to trial.
- The trial court awarded the marital home to Wife, used the filing date for the home's value and the trial date for the mortgage value, and ordered an equal split of home equity.
- Husband made almost two years of mortgage payments post-separation; Wife paid for some repairs and upkeep.
- The court ordered Husband to pay monthly retroactive durational alimony without findings on Wife’s expenses.
- Husband appealed the equitable-distribution scheme, denial of mortgage payment credits, alimony award, and resultant support burden.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Valuation Date for Marital Home | Filing date benefited Wife unfairly; trial date proper | Chose filing date due to her maintenance role | Court: Use trial date since Wife didn’t solely contribute to value increase; reversed and remanded. |
| Credits for Mortgage Payments | Entitled to credit for post-separation payments | His misconduct justifies denying credits | Court: Credits generally required; no findings made to justify denying; reversed and remanded. |
| Unequal Equitable Distribution | Trial court’s errors resulted in unequal distribution | (No specific argument by Wife) | Court: Unequal distribution not properly justified in findings; reversed for reconsideration and findings. |
| Alimony Award Findings | No findings on Wife’s expenses/need; error | N/A | Court: Award must be based on specific findings of need and ability to pay; reversed alimony and remanded. |
Key Cases Cited
- Moses v. Moses, 347 So. 3d 385 (Fla. 5th DCA 2021) (abuse of discretion and requirement for findings in equitable distribution)
- Brutus v. Giles, 360 So. 3d 1223 (Fla. 5th DCA 2023) (limitations on trial court discretion)
- Erdman v. Erdman, 301 So. 3d 316 (Fla. 5th DCA 2019) (valuation date for marital assets depends on parties’ contributions)
- Roth v. Roth, 312 So. 3d 1021 (Fla. 2d DCA 2021) (valuation date and sole party upkeep)
- Fairchild v. Fairchild, 135 So. 3d 537 (Fla. 5th DCA 2014) (entitlement to mortgage payment credits)
- Barrett v. Barrett, 313 So. 3d 224 (Fla. 5th DCA 2021) (requirement for findings on alimony need and amount)