Koski v. Koski

The former husband appeals an order denying his supplemental petition for modification of alimony. Because we are unable to determine if the trial court considered all applicable section 61.08(2) factors before concluding that the former husband’s alimony obligation should remain unchanged despite a substantial increase in the former wife’s earnings, we reverse and remand for further proceedings.

In 2003, the trial court entered an amended final judgment of dissolution of marriage, dissolving the parties’ nineteen-year marriage. In that judgment, the trial court found that the former husband’s…