In the absence of factual findings, a trial court’s decision may be overturned. As in Jalileyan
v. Jalileyan, 4 So.3d 1289 (Fla. 4th DCA 2009), the equitable distribution award was reversed
because the final judgment indicated that the trial court made an unequal distribution of the marital
assets, mainly by awarding the marital residence to the former wife, yet failed to make factual
findings to explain or justify the disproportionate equitable distribution. Similarly, in Austin v.
Austin, 12 So.3d 314 (Fla. 2d DCA 2009), the trial court ordered all marital liabilities to be equally
divided without providing identification of each liability and without identifying which party was
responsible for each liability. Such a distribution is not permitted.
In Williams v. Williams, 133 So.3d 605 (Fla. 1st DCA 2014), the First District was unable
to determine how the trial court valued the parties’ art collection at $376,086, when the former
husband’s expert witness appraised it at $470,107 and the former wife’s expert witness appraised it
at $688,550. The issue was therefore reversed and remanded for the trial court to explain how it
reached the value it placed on the collection and to set forth a value as to the pieces housed in
Florida. See Blossman v. Blossman, 92 So.3d 878, 879 (Fla. 1st DCA 2012); Wendroff v. Wendroff,
614 So.2d 590 (Fla. 1st DCA 1993); Augoshe v. Lehman, 962 So.2d 398, 402–03 (Fla. 2d DCA
2007). Additionally, as to the equalization payment the court awarded to the wife, the final
judgment does not indicate how the trial court reached the figure of $195,507 for this payment. The
judgment states only that the figure included the Social Security checks, the withdrawal from the
joint bank account, and the FEMA payment. These items do not total the amount of the equalization
payment, and there are no findings or explanation in the final judgment as to how the court reached
the amount of the equalization payment.
A trial court must support any distribution of marital assets or liabilities with factual findings
in the judgment, based on competent substantial evidence, with reference to the statutory factors.
See § 61.075(3), Fla. Stat.; Winney v. Winney, 979 So.2d 396 (Fla. 1st DCA 2008); Nicewonder v.
Nicewonder, 602 So.2d 1354 (Fla. 1st DCA 1992). It must make specific written findings of fact
identifying marital assets and individually valuing significant assets. See § 61.075(3)(b), Fla. Stat.;
Bateh v. Bateh, 98 So.3d 750, 753 (Fla. 1st DCA 2012); Wendroff v. Wendroff, 614 So.2d 590,
593–94 (Fla. 1st DCA 1993). The lack of any such findings in the final judgment made meaningful
appellate review of the equalization payment impossible. Williams v. Williams, 133 So.3d 605 (Fla.
1st DCA 2014); Callwood v. Callwood, 221 So.3d 1198 (Fla. 4
th
DCA 2017); Vaughn v. Vaughn,
250 So.3d 126 (Fla. 4
th
DCA 2018).
See also Fernandez-Tretiakova v. Fernandez, 313 So. 3d 623 (Fla. 4th DCA 2021), noting
that reversible error occurs where the equitable distribution in the final judgment is not supported
by factual findings with reference to the factors listed in section 61.075(1), as required by section
61.075(3) when ‘a stipulation and agreement has not been entered and filed.’” Richardson v.
Knight, 197 So. 3d 143 (Fla. 4th DCA 2016) (quoting § 61.075(3), Fla. Stat.); see also Rodriguez
v. Rodriguez, 994 So. 2d 1157 (Fla. 3d DCA 2008). In Fernandez, the only reference to section
61.075(1), Florida Statutes, in the final judgment was where the trial court stated: [t]he
Court finds that the wife has established a need for and that the husband has the present