Leone v. Leone

Appellant, Pamela A. Leone (Wife), appeals an order granting her former counsel attorney’s fees pursuant to an attorney’s charging lien. We reverse and remand.

Florida courts have held that an attorney's charging lien should not be enforced against an award of alimony if to do so would deprive a former spouse of daily sustenance or the minimal necessities of life. Zimmerman v. Livnat, 507 So.2d 1205 (Fla. 4th DCA 1987); Brake v. Sanchez-Lopez, 452 So.2d 1071 (Fla. 3d DCA 1984); Dyer v. Dyer, 438 So.2d 954 (Fla. 4th DCA 1983).

In the present case, the final judgment of dissolution of marriage…