George Jack Beck v. Monika Tamas-Beck

OCR transcription; preserved printed pages are authoritative

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT

GEORGE JACK BECK,
Appellant,

Vv.

MONIKA TAMAS-BECK,
Appellee.

No. 4D2024-0814
[November 19, 2025]

Appeal from the Circuit Court for the Seventeenth Judicial Circuit,
Broward County; Michael Davis, Judge; L.T. Case No. FMCE22003528.

Kristin A. West of The Law Offices of Kristin A. West, P.A., Fort
Lauderdale, for appellant.

Nancy A. Hass of Nancy A. Hass, P.A., Hollywood, for appellee.
SHEPHERD, J.

The former husband appeals the final judgment of dissolution of
marriage. He raises three arguments on appeal. For the reasons
discussed below, we reverse on the former husband’s first and second
arguments, but affirm on the third argument without discussion.

First, the former husband argues that the trial court, without making
the required factual findings, ordered him to obtain life insurance to
secure support. We agree such findings are required. “A trial court has
the authority to order a party to obtain life insurance to secure the
payment of alimony and child support.” §§ 61.08(3), 61.13(1)(c) Fla. Stat.
(2023). However, “the trial court must make specific evidentiary findings
regarding the availability and cost of insurance, the obligor's ability to pay,
and the special circumstances that warrant the requirement for security
of the obligation.” Leyte-Vidal v. Leyte-Vidal, 350 So. 3d 79, 83 (Fla. 4th
DCA 2022); see also Zvida v. Zvida, 103 So. 3d 1052, 1054 (Fla. 4th DCA
2013) (failure to make the necessary findings to support an order requiring
the maintenance of life insurance to secure the payment of alimony or
child support constitutes reversible error). Here, the trial court’s
seventeen-page final judgment omits the required findings regarding life

insurance. Thus, we reverse the trial court’s order directing the former
husband to obtain life insurance, and remand for the court to make the
required findings before considering whether to reinstate the order.

Second, the former husband argues that the trial court erred in the
award of durational alimony because the trial court had miscalculated the
duration of the parties’ marriage. We agree with this argument as well.
The record reflects the parties were married from May 15, 2013 to March
16, 2022 (i.e., 106 months). Section 61.08(8)(b), Florida Statutes (2023),
provides: “An award of durational alimony may not exceed 50% of the
length of a short-term marriage.” § 61.08(8)(b), Fla. Stat. (2023). Section
61.08(5) defines short-term marriages as those marriages with a duration
of less than ten years. § 61.08(5), Fla. Stat. (2023); see also Whyte v.
Whyte, 337 So. 3d 18, 20 (Fla. 4th DCA 2022); Diaz v. Diaz, 152 So. 3d
743, 744 (Fla. 3d DCA 2014). Accordingly, we reverse and remand for the
trial court to amend the final judgment to reduce the durational alimony
award from fifty-four months to fifty-three months.

Affirmed in part, reversed in part, and remanded for proceedings
consistent with this opinion.

GROSS and May, JJ., concur.

* * *

Not final until disposition of timely-filed motion for rehearing.