Case: Tanner v. Tanner (2021) – 1st DCA
Issue: Findings required for maintaining life insurance to secure payment of alimony.
Ruling: Although a trial court may order an obligor to “purchase or maintain a life insurance policy or a bond, or to otherwise secure” an alimony award. § 61.08(3), Fla. Stat. (2020). A trial court may not require an obligor to maintain security unless it makes a specific finding that special circumstances exist. Mackoul v. Mackoul, 32 So. 3d 741, 742 (Fla. 1st DCA 2010).