Manko v. Manko

Timothy J. Manko appeals the trial court's order holding him in contempt and denying his motion to abate his support obligations owed to Laurie Manko. We affirm the trial court's order save for the award of attorney's fees. We are compelled to reverse the attorney's fees award because the trial court failed to make a determination as to need and ability to pay. See Jones v. Jones, 671 So.2d 852, 854-55 (Fla. 5th DCA 1996) (reiterating that trial court must consider need and ability to pay under section 61.16, Florida Statutes, *850in order to award attorney's fees in post-dissolution contempt…