Background
Brenton L. Redcross, the former husband, appealed a final judgment entered by the Circuit Court for the Fifteenth Judicial Circuit in Palm Beach County. Both former spouses represented themselves on appeal.
The final judgment mistakenly directed the former husband to pay child support to the former wife between January 1, 2025, and November 30, 2026. The judgment otherwise established that those payments were the former wife’s obligations. The final judgment also did not have a copy of the final parenting plan attached.
The Court’s Holding
The Fourth District Court of Appeal affirmed the final judgment in all respects. It nevertheless remanded the case with instructions to correct the scrivener’s error identifying which former spouse owed child support during the specified period.
The court also instructed the trial court to attach a copy of the final parenting plan to the final judgment. In doing so, it relied on Sadlak v. Trujillo, 336 So. 3d 1275, 1280 (Fla. 3d DCA 2022).
Key Takeaways
- The appellate court affirmed the substance of the final judgment.
- The trial court must correct the judgment to reflect that the former wife—not the former husband—was obligated to pay child support from January 1, 2025, through November 30, 2026.
- The trial court must attach the final parenting plan to the final judgment.
Why It Matters
The decision shows that an appellate court may affirm a family-law judgment while remanding for correction of a clerical error that inaccurately identifies the party responsible for child support. It also underscores the need to incorporate the operative parenting plan into the final judgment by attachment.