Liberatore v. Liberatore

Marcee Liberatore appeals an order that disbursed certain marital assets and liabilities, arguing that it violated this Court’s mandate in Liberatore v. Liberatore, 101 So.3d 1290 (Fla. 5th DCA 2012). We agree, and thus, reverse.

In the initial appeal, this Court addressed whether the trial court erred in distributing depleted marital assets in an equitable distribution scheme without a finding of misconduct. We found that the *77trial court erred, and reversed and remanded for reconsideration of the distribution scheme to address this issue.

On remand, a lower court must strictly follow the…