Rogers v. Wiggins

KELLY, Judge.

Alayna Rogers (the mother) challenges the trial court’s order requiring her to pay Sean Stacy Wiggins’s (the father’s) attorney’s fees incurred in defending against the mother’s amended supplemental petition to modify child custody. We reverse the award of fees because the trial court erred in its consideration of the factors set forth under section 61.16, Florida Statutes (2014).

The parties are the parents of a daughter who was born in 2005. They had a rocky relationship and never married. Originally, the mother was designated as the primary residential parent; however, she…