Department of Revenue ex rel. Satchell v. Satchell

The Department of Revenue contends that the trial court erred in ordering the former wife (the nonprevailing obligee) to pay attorney’s fees and costs to the former husband (the prevailing obligor) after determining that the post-dissolution proceedings on the former husband’s motion to determine child support arrearage and overpayment did not constitute an action under Title IV-D of the Social Security Act. Pursuant to section 61.16(1), Florida Statutes (2001), a prevailing obligor is not entitled to recover attorney’s fees and costs from a nonprevailing obligee in a Title TV-D case. See…