Former Wife’s Long-Term Relationship Constitutes a “Supportive Relationship” Under Florida Law


In a recent decision, the Florida Third District Court of Appeal held that a former wife’s long-term relationship with her boyfriend constituted a “supportive relationship” under Florida law. This means that the former wife’s alimony payments could be reduced or terminated.

The case, Curtis John Proveaux, Sr. v. Betty Ann Proveaux, involved a couple who divorced in 1995. The former husband was ordered to pay permanent weekly alimony payments to the former wife. In 2020, the former husband petitioned to modify his alimony payments, alleging that the former wife was in a supportive relationship with her boyfriend.

A bench trial was held on the former husband’s petition. The evidence showed that the former wife and her boyfriend had been in a committed, serious relationship for at least fourteen years, and had been living together since before 2009. They had jointly purchased property and pooled their assets. The joint purchase of their shared residence was a significant factor in the court’s finding that a supportive relationship existed.

The court also found that the former wife and her boyfriend shared household chores, household expenses, and grocery expenses. They also took turns buying meals when they went out to eat. 

Despite these findings, the trial court found that a supportive relationship had not been shown, believing that there must be a significant financial benefit confirmed between the supportive couple.  

The Court of Appeal’s reversed, finding that a supportive relationship existed.  The Court of Appeal’s decision is significant because it clarifies the factors that courts will consider in determining whether a former spouse is in a supportive relationship, and that not each statutory factor need be shown for the court to find that a supportive relationship exists.  

If you are instructed in a list of the statutory factors a court is to use in determining the existence of a supportive relationship, here is the link to Section 61.14(1)(b)2, Florida Statutes


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