Caffin v. Caffin

COWART, Judge.

We construe the modification award of exclusive possession of the husband’s one-half interest in the prior marital home to the wife for life to be the adjudication of a spousal support obligation (of shelter in kind) which is always subject to modification on a showing of a substantial change in circumstances. As construed, we uphold this support award because it is based on a finding by the trial court of the wife’s need and the husband’s ability which is a factual finding with a presumption of correctness. See Kuvin v. Kuvin, 442 So.2d 203 (Fla. 1983); Conner v. Conner, 439…