Supportive Relationships – Florida makes it easier to terminate alimony

Florida allows alimony to be reduced or terminated if the spouse receiving alimony lives in a “Support Relationship” with their boyfriend or girlfriend.* 

What is a Supportive Relationship?  The statue providing the definition of a Supportive Relationship lists a number of red flags indicators.  The pooling of income and assets is often perceived as one of the most important indicators.  So an open question has been whether a Supportive Relationship can be found when the former spouse and their boyfriend or girlfriend do not comingle their bank accounts.  

In a recent decision Florida’s 5th DCA answered this question with a “yes.” ** A Supportive Relationship can be found by a court even if their has been no comingling of bank accounts.

What was the key determination from the 5th DCA’s perspective?  The Court found that was in fact a Supportive Relationship when “all things considered”  the  “parties were living in the substantial equivalent of a marriage.”   

From a practical standpoint I this decision will make it easier for the spouse paying alimony to claim the existence of  Supportive Relationship because it encourage the Court to look at the relationship as a whole rather than simply tick off the factors listed as red flags in the statute.   


Section 61.14, Florida Statutes (2021).  

**  Klowkow v. Klowkow

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