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Florida Statute 61.21 - Full Text and Legal Analysis
Florida Statute 61.21 | Lawyer Caselaw & Research
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The 2025 Florida Statutes

Title VI
CIVIL PRACTICE AND PROCEDURE
Chapter 61
DISSOLUTION OF MARRIAGE; SUPPORT; TIME-SHARING
View Entire Chapter
61.21 Parenting course authorized; fees; required attendance authorized; contempt.
(1) LEGISLATIVE FINDINGS; PURPOSE.It is the finding of the Legislature that:
(a) A large number of children experience the separation or divorce of their parents each year. Parental conflict related to divorce is a societal concern because children suffer potential short-term and long-term detrimental economic, emotional, and educational effects during this difficult period of family transition. This is particularly true when parents engage in lengthy legal conflict.
(b) Parents are more likely to consider the best interests of their children when determining parental arrangements if courts provide families with information regarding the process by which courts make decisions on issues affecting their children and suggestions as to how parents may ease the coming adjustments in family structure for their children.
(c) It is beneficial to parents who are separating or divorcing to have available an educational program that will provide general information regarding:
1. The issues and legal procedures for resolving time-sharing and child support disputes.
2. The emotional experiences and problems of divorcing adults.
3. The family problems and the emotional concerns and needs of the children.
4. The availability of community services and resources.
(d) It is also beneficial to divorcing or separating parents of children who have identified special needs or emotional concerns to have available an educational program that will provide information tailored to children who have special needs or emotional concerns.
(e) Parents who are separating or divorcing are more likely to receive maximum benefit from a program if they attend such program at the earliest stages of their dispute, before extensive litigation occurs and adversarial positions are assumed or intensified.
(2) The Department of Children and Families shall approve a parenting course which must be a minimum of 4 hours and designed to educate, train, and assist divorcing parents in regard to the consequences of divorce on parents and children.
(a) The parenting course referred to in this section is named the Parent Education and Family Stabilization Course and may include, but need not be limited to, the following topics as they relate to court actions between parents involving custody, care, time-sharing, and support of a child or children:
1. Legal aspects of deciding child-related issues between parents.
2. Emotional aspects of separation and divorce on adults.
3. Emotional aspects of separation and divorce on children.
4. Family relationships and family dynamics.
5. Financial responsibilities to a child or children.
6. Issues regarding spousal or child abuse and neglect.
7. Skill-based relationship education that may be generalized to parenting, workplace, school, neighborhood, and civic relationships.
8. Particularized needs of children who have identified special needs or emotional concerns.
(b) Information regarding spousal and child abuse and neglect shall be included in every parent education and family stabilization course. A list of local agencies that provide assistance with such issues shall also be provided.
(c) The parent education and family stabilization course shall be educational in nature and shall not be designed to provide individual mental health therapy for parents or children, or individual legal advice to parents or children.
(d) Course providers shall not solicit participants from the sessions they conduct to become private clients or patients.
(e) Course providers shall not give individual legal advice or mental health therapy.
(3) Each course provider offering a parenting course pursuant to this section must be approved by the Department of Children and Families.
(a) The Department of Children and Families shall provide each judicial circuit with a list of approved course providers and sites at which the parent education and family stabilization course may be completed. Each judicial circuit must make information regarding all course providers approved for their circuit available to all parents.
(b) The Department of Children and Families shall include on the list of approved course providers and sites for each circuit at least one site in that circuit where the parent education and family stabilization course may be completed on a sliding fee scale, if available.
(c) The Department of Children and Families shall include on the list of approved course providers, without limitation as to the area of the state for which the course is approved, a minimum of one statewide approved course to be provided through the Internet and one statewide approved course to be provided through correspondence. The purpose of the Internet and correspondence courses is to ensure that the parent education and stabilization course is available in the home county of each state resident and to those out-of-state persons subject to this section.
(d) The Department of Children and Families may remove a provider who violates this section, or its implementing rules, from the list of approved court providers.
(e) The Department of Children and Families shall adopt rules to administer subsection (2) and this subsection.
(4)(a) All parties to a dissolution of marriage proceeding with minor children or a paternity action that involves issues of parental responsibility shall complete the Parent Education and Family Stabilization Course before the entry by the court of a final judgment. If the parties have children who have identified special needs or emotional concerns, the parties must select a Parent Education and Family Stabilization Course that is tailored to education relating to children who have special needs or emotional concerns.
(b) The court may excuse a party from attending the parenting course, or from completing the course within the required time, for good cause.
(5) All parties required to complete a parenting course under this section shall begin the course as expeditiously as possible. For dissolution of marriage actions, unless excused by the court pursuant to subsection (4), the petitioner must complete the course within 45 days after the filing of the petition, and all other parties must complete the course within 45 days after service of the petition. For paternity actions, unless excused by the court pursuant to subsection (4), the petitioner must complete the course within 45 days after filing the petition, and any other party must complete the course within 45 days after an acknowledgment of paternity by that party, an adjudication of paternity of that party, or an order granting time-sharing to or support from that party. Each party to a dissolution or paternity action shall file proof of compliance with this subsection with the court prior to the entry of the final judgment.
(6) All parties to a modification of a final judgment involving a parenting plan or a time-sharing schedule may be required to complete a court-approved parenting course prior to the entry of an order modifying the final judgment.
(7) A reasonable fee may be charged to each parent attending the course.
(8) Information obtained or statements made by the parties at any educational session required under this statute shall not be considered in the adjudication of a pending or subsequent action, nor shall any report resulting from such educational session become part of the record of the case unless the parties have stipulated in writing to the contrary.
(9) The court may hold any parent who fails to attend a required parenting course in contempt, or that parent may be denied shared parental responsibility or time-sharing or otherwise sanctioned as the court deems appropriate.
(10) Nothing in this section shall be construed to require the parties to a dissolution of marriage to attend a court-approved parenting course together.
(11) The court may, without motion of either party, prohibit the parenting course from being taken together, if there is a history of domestic violence between the parties.
(12) The court, in its discretion, may require a parent to attend educational courses relating to children who have special needs or emotional concerns in addition to the Parent Education and Family Stabilization Course required under this section.
History.s. 1, ch. 94-185; s. 13, ch. 98-403; s. 75, ch. 2003-402; s. 8, ch. 2005-239; s. 15, ch. 2008-61; s. 7, ch. 2009-180; s. 24, ch. 2014-19; s. 3, ch. 2021-103.

F.S. 61.21 on Google Scholar

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Amendments to 61.21


Annotations, Discussions, Cases:

Cases Citing Statute 61.21

Total Results: 79  |  Sort by: Relevance  |  Newest First

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Shiffman v. Askew, 359 F. Supp. 1225 (M.D. Fla. 1973).

Cited 22 times | Published | District Court, M.D. Florida | 1973 U.S. Dist. LEXIS 13385

challenge the constitutionality of Florida Statute § 61.021 (1971), F.S.A. A provision familiar to all lawyers
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Arjona v. Torres, 941 So. 2d 451 (Fla. 3d DCA 2006).

Cited 15 times | Published | Florida 3rd District Court of Appeal | 2006 WL 3019578

argument, but participated in the decision. [2] Section 61.021, Florida Statutes (2002), titled "Residence
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In Re Fam. Law Rules of Procedure, 663 So. 2d 1049 (Fla. 1995).

Cited 15 times | Published | Supreme Court of Florida | 20 Fla. L. Weekly Supp. 581, 1995 Fla. LEXIS 1953, 1995 WL 689537

for 6 months before filing the petition. See section 61.021, Florida Statutes. Residence may be proved
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Gillman v. Gillman, 413 So. 2d 412 (Fla. 4th DCA 1982).

Cited 15 times | Published | Florida 4th District Court of Appeal

Florida for six months before filing the petition. § 61.021, Fla. Stat. (1971). Evidence as to Florida residence
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McDougald v. Jenson, 596 F. Supp. 680 (N.D. Fla. 1984).

Cited 14 times | Published | District Court, N.D. Florida | 1984 U.S. Dist. LEXIS 23272

of divorce and child custody matters under Section 61.021, Florida Statutes, is deemed to mean both residence
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Fernandez v. Fernandez, 648 So. 2d 712 (Fla. 1995).

Cited 12 times | Published | Supreme Court of Florida | 1995 WL 8963

prior to the filing of a petition for dissolution. § 61.021, Fla. Stat. (1991). Further, evidence establishing
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McCabe v. McCabe, 600 So. 2d 1181 (Fla. 5th DCA 1992).

Cited 9 times | Published | Florida 5th District Court of Appeal | 1992 WL 106958

his petition for dissolution as required by section 61.021 of the Florida Statutes (1991),[1] this fact
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Eckel v. Eckel, 522 So. 2d 1018 (Fla. 1st DCA 1988).

Cited 9 times | Published | Florida 1st District Court of Appeal | 1988 WL 27799

has satisfied the residency requirements of Section 61.021, Florida Statutes, we reverse the order of
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Maldonado v. Allstate Ins. Co., 789 So. 2d 464 (Fla. 2d DCA 2001).

Cited 8 times | Published | Florida 2nd District Court of Appeal | 2001 Fla. App. LEXIS 9027, 2001 WL 726002

of them has been a resident for six months. See § 61.021, Fla. Stat. (2000). When a statute requires such
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Lande v. Lande, 2 So. 3d 378 (Fla. 4th DCA 2008).

Cited 8 times | Published | Florida 4th District Court of Appeal | 2008 Fla. App. LEXIS 19360, 2008 WL 5352144

resident of Florida since October of 2000. See § 61.021, Fla. Stat. (2007) ("to obtain a dissolution of
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Orbe v. Orbe, 651 So. 2d 1295 (Fla. 5th DCA 1995).

Cited 7 times | Published | Florida 5th District Court of Appeal | 20 Fla. L. Weekly Fed. D 705

spouse in Florida prior to filing the petition). § 61.021, Fla. Stat. (1993); Perez v. Perez, 519 So.2d
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Nicolas v. Nicolas, 444 So. 2d 1118 (Fla. 3d DCA 1984).

Cited 7 times | Published | Florida 3rd District Court of Appeal

six-month residency requirement established by Section 61.021, Florida Statutes (1981), for bringing a marriage
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Amendments to the Florida Fam. Law Rules, 713 So. 2d 1 (Fla. 1998).

Cited 7 times | Published | Supreme Court of Florida | 23 Fla. L. Weekly Supp. 105, 1998 Fla. LEXIS 475, 1998 WL 166533

defined there. For further information, see section 61.021, Florida Statutes or section 61.052(2), Florida
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Goodwin v. Goodwin, 559 So. 2d 109 (Fla. 2d DCA 1990).

Cited 7 times | Published | Florida 2nd District Court of Appeal | 1990 WL 38712

to the filing of his petition as required by section 61.021, Florida Statutes (1989). The establishment
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Beaucamp v. Beaucamp, 508 So. 2d 419 (Fla. 2d DCA 1987).

Cited 6 times | Published | Florida 2nd District Court of Appeal | 12 Fla. L. Weekly 1207

preceding the filing of her petition for dissolution. § 61.021, Fla. Stat. (1983). When the parties met and married
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In Re Report of Fam. Ct. Steering Comm., 794 So. 2d 518 (Fla. 2001).

Cited 6 times | Published | Supreme Court of Florida | 2001 WL 1034530

...in crisis. Screening and subsequent service referrals will ensure that all presenting issues are clearly focused and that families are provided with an opportunity to resolve their disputes before engaging in destructive adversarial litigation. See § 61.21(1)(d), Fla....
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Birnbaum v. Birnbaum, 615 So. 2d 241 (Fla. 3d DCA 1993).

Cited 6 times | Published | Florida 3rd District Court of Appeal | 1993 WL 63484

in the state before the filing of the petition. § 61.021, Fla. Stat. (1991). Additionally, the party must
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Jenkins v. Jenkins, 556 So. 2d 441 (Fla. 4th DCA 1990).

Cited 6 times | Published | Florida 4th District Court of Appeal | 1990 WL 2698

a dissolution action in Florida pursuant to section 61.021, Florida Statutes (1986). "Residence" for purposes
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Wise v. Wise, 310 So. 2d 431 (Fla. 1st DCA 1975).

Cited 6 times | Published | Florida 1st District Court of Appeal

for six months before filing the petition. Section 61.021, Florida Statutes. Residence for the statutory
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Curran v. Curran, 362 So. 2d 1042 (Fla. 4th DCA 1978).

Cited 5 times | Published | Florida 4th District Court of Appeal

marriage. The question is one of jurisdiction and Section 61.021, Florida Statutes which requires residency
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Sheppard v. Sheppard, 286 So. 2d 37 (Fla. 1st DCA 1973).

Cited 5 times | Published | Florida 1st District Court of Appeal

of Florida for six months as required by F.S. § 61.021, F.S.A., in order to maintain an action for dissolution
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Shammay v. Shammay, 491 So. 2d 284 (Fla. 3d DCA 1986).

Cited 5 times | Published | Florida 3rd District Court of Appeal

So.2d 412 (Fla. 4th DCA 1982) (interpreting section 61.021, Florida Statutes (1971) as requiring the party
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Snyder v. McLeod, 971 So. 2d 166 (Fla. 5th DCA 2007).

Cited 5 times | Published | Florida 5th District Court of Appeal | 2007 WL 4547394

most often arises in divorce cases, because section 61.021, Florida Statutes, requires that one of the
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Minda v. Minda, 190 So. 3d 1126 (Fla. 2d DCA 2016).

Cited 5 times | Published | Florida 2nd District Court of Appeal | 2016 WL 1718854, 2016 Fla. App. LEXIS 6621

residents of Florida within the meaning of section 61.021, Florida Statutes (2014), that the former husband
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Amendments to the Florida Fam. Law Rules of Procedure & Fam. Law Forms, 810 So. 2d 1 (Fla. 2000).

Cited 4 times | Published | Supreme Court of Florida | 26 Fla. L. Weekly Supp. 13, 2000 Fla. LEXIS 2272, 2000 WL 1352932

defined there. For further information, see section 61.021, Florida Statutes or section 61.052(2), Florida
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Caizza v. Caizza, 291 So. 2d 569 (Fla. 1974).

Cited 4 times | Published | Supreme Court of Florida

held that the residency requirement of Fla. Stat. § 61.021, F.S.A., was constitutional. We have jurisdiction
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Rowland v. Rowland, 868 So. 2d 608 (Fla. 2d DCA 2004).

Cited 4 times | Published | Florida 2nd District Court of Appeal | 2004 WL 503755

establish Florida residency. "Residency under section 61.021[, Florida Statutes (1998),] means `an actual
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Coons v. Coons, 765 So. 2d 167 (Fla. 1st DCA 2000).

Cited 4 times | Published | Florida 1st District Court of Appeal | 2000 WL 889843

filing of the petition. § 61.021, Fla. Stat. (1997). "Compliance with the section 61.021 residence requirement
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Silvestri v. Silvestri, 309 So. 2d 29 (Fla. 3d DCA 1975).

Cited 4 times | Published | Florida 3rd District Court of Appeal

the six months residency requirement under Fla. Stat. 61.021, F.S.A. In addition, Dr. Silvestri suggests
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Lopes v. Lopes, 852 So. 2d 402 (Fla. 5th DCA 2003).

Cited 4 times | Published | Florida 5th District Court of Appeal | 2003 WL 21990210

requirement imposed by Florida law to obtain a divorce. § 61.021, Fla. Stat. (1999). Florida courts have determined
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Gordon v. Gordon, 369 So. 2d 421 (Fla. 3d DCA 1979).

Cited 4 times | Published | Florida 3rd District Court of Appeal

period which is requisite to jurisdiction under Section 61.021, Florida Statutes (1977). The plaintiff-wife
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Copas v. Copas, 687 So. 2d 885 (Fla. 2d DCA 1997).

Cited 3 times | Published | Florida 2nd District Court of Appeal | 1997 WL 30296

finding she was not a resident of Florida. Section 61.021, Florida Statutes (1993), requires that one
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Rudel v. Rudel, 111 So. 3d 285 (Fla. 4th DCA 2013).

Cited 3 times | Published | Florida 4th District Court of Appeal | 2013 WL 1629167, 2013 Fla. App. LEXIS 6059

did not satisfy the residency requirement of section 61.021, Florida Statutes. The court’s determination
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Hoffman v. Hoffman, 552 So. 2d 958 (Fla. 1st DCA 1989).

Cited 2 times | Published | Florida 1st District Court of Appeal | 1989 WL 135521

husband next before the filing of the action. Section 61.021, Florida Statutes. Though there was much conflicting
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McCarthy v. Alexander, 786 So. 2d 1284 (Fla. 2d DCA 2001).

Cited 2 times | Published | Florida 2nd District Court of Appeal | 2001 WL 698141

the state before the filing of the petition." § 61.021, Fla. Stat. (1997). Although this requirement
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Hunter v. Hunter, 736 So. 2d 801 (Fla. 1st DCA 1999).

Cited 2 times | Published | Florida 1st District Court of Appeal | 1999 WL 497505

did not satisfy the residency requirement of section 61.021, Florida Statutes (1997), and (ii) that the
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Jenkins v. Jenkins, 915 So. 2d 1248 (Fla. 4th DCA 2005).

Cited 2 times | Published | Florida 4th District Court of Appeal | 2005 WL 3479496

filing a petition for dissolution of marriage. See § 61.021, Fla. Stat. (2004). Proof of residency "may be
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Walsh v. Walsh, 388 So. 2d 240 (Fla. 2d DCA 1980).

Cited 2 times | Published | Florida 2nd District Court of Appeal

02, Florida Statutes (1965) (now appearing at § 61.021, Fla. Stat. [1979]). The court therefore, had
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Amendments to Fl. Fam. Law Rules of Proc., 940 So. 2d 409 (Fla. 2006).

Cited 1 times | Published | Supreme Court of Florida

defined there. For further information, see section 61.021, Florida Statutes or section 61.052(2), Florida
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Franks v. Franks, 86 So. 3d 1252 (Fla. 1st DCA 2012).

Cited 1 times | Published | Florida 1st District Court of Appeal | 2012 WL 1559696, 2012 Fla. App. LEXIS 6997

before the petition for dissolution was filed. See § 61.021, Fla. Stat. (2010). In addition, although the
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Bouquety v. Bouquety, 933 So. 2d 610 (Fla. 3d DCA 2006).

Cited 1 times | Published | Florida 3rd District Court of Appeal | 2006 WL 1751752

residency requirement prior to the filing. See § 61.021, Fla. Stat. (2000). The parties do not dispute
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Weber v. Weber, 929 So. 2d 1165 (Fla. 2d DCA 2006).

Cited 1 times | Published | Florida 2nd District Court of Appeal | 2006 WL 1506246

for dissolution of marriage, as required by section 61.021, Florida Statutes (2004). We deny the petition
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Speigner v. Speigner, 621 So. 2d 758 (Fla. 1st DCA 1993).

Cited 1 times | Published | Florida 1st District Court of Appeal | 1993 WL 242659

compliance with the residence requirement of section 61.021, Florida Statutes (1991); (2) whether the trial
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Weinschel v. Weinschel, 368 So. 2d 386 (Fla. 3d DCA 1979).

Cited 1 times | Published | Florida 3rd District Court of Appeal

met the six month Florida residency requirement. § 61.021, Fla. Stat. (1977). No appeal was taken from this
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Lefkovitz v. Lefkovitz, 341 So. 2d 253 (Fla. 1st DCA 1976).

Cited 1 times | Published | Florida 1st District Court of Appeal

after satisfying the residency requirement of § 61.021, F.S. 1973, the husband instituted his own dissolution
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In re Amendments to the Florida Fam. Law Rules of Procedure, 940 So. 2d 409 (Fla. 2006).

Published | Supreme Court of Florida | 31 Fla. L. Weekly Supp. 627, 2006 Fla. LEXIS 2366, 2006 WL 2771540

defined there. For further information, see section 61.021, Florida Statutes or section 61.052(2), Florida
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Morse v. Morse, 796 So. 2d 1200 (Fla. 3d DCA 2001).

Published | Florida 3rd District Court of Appeal | 2001 Fla. App. LEXIS 13434, 2001 WL 1132057

satisfy the residency requirements set forth in section 61.021, Florida Statutes (1997). See Fernandez v.
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Carson v. Carson, 226 So. 3d 374 (Fla. 5th DCA 2017).

Published | Florida 5th District Court of Appeal | 2017 WL 4103217, 2017 Fla. App. LEXIS 13197

...designated weekends or holidays. At this stage of the proceedings, a compliant parent can be ordered to attend such a course only if there is a modification of a final judgment involving a parenting plan or modification of a timesharing schedule. § 61.21, Fla....
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Hasslacher v. Hasslacher, 664 So. 2d 993 (Fla. Dist. Ct. App. 1995).

Published | District Court of Appeal of Florida | 1995 Fla. App. LEXIS 10398, 1995 WL 581135

matter of law, the jurisdictional requirement of section 61.021, Florida Statutes (1993), cannot be met. Other
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Vinsand v. Vinsand, 179 So. 3d 366 (Fla. 2d DCA 2015).

Published | Florida 2nd District Court of Appeal | 2015 Fla. App. LEXIS 19727, 2015 WL 6503442

obtaining a divorce in this state. See § 61.021, Fla. Stat. (2012) (“To obtain a dissolution of
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Mikulec v. Mikulec, 47 So. 3d 851 (Fla. 4th DCA 2010).

Published | Florida 4th District Court of Appeal | 2010 Fla. App. LEXIS 15551, 2010 WL 3984746

matter jurisdiction in a divorce proceeding, section 61.021, Florida Statutes, provides that "one of the
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Polonsky v. Polonsky, 303 So. 2d 64 (Fla. 4th DCA 1974).

Published | Florida 4th District Court of Appeal | 1974 Fla. App. LEXIS 8253

fulfilled the six month residency requirement of F. S. 61.021. The husband’s motion was based upon the procedure
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Kopecky v. Kopecka, 967 So. 2d 1109 (Fla. 4th DCA 2007).

Published | Florida 4th District Court of Appeal | 2007 Fla. App. LEXIS 18148, 2007 WL 3355576

the state before the filing of the petition.” § 61.021, Fla. Stat. (2007). The husband has resided in
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Hamilton v. Michieli, 954 So. 2d 739 (Fla. 3d DCA 2007).

Published | Florida 3rd District Court of Appeal | 2007 Fla. App. LEXIS 6619, 2007 WL 1263492

months preceding the filing of the petition. Section 61.021 of the Florida Statutes requires “one of the
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Markofsky v. Markofsky, 384 So. 2d 38 (Fla. 3d DCA 1980).

Published | Florida 3rd District Court of Appeal | 1980 Fla. App. LEXIS 16859

Perez v. Perez, 164 So.2d 561 (Fla. 3d DCA 1964); § 61.021, Fla.Stat. (1979); and (b) the trial court was
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Roman v. Lopez, 811 So. 2d 840 (Fla. 3d DCA 2002).

Published | Florida 3rd District Court of Appeal | 2002 Fla. App. LEXIS 3924, 2002 WL 460398

...ER CURIAM. Anangelica Roman, a petitioner for injunction for protection against domestic violence, appeals the trial court’s order requiring her to attend parenting classes. We reject her argument that attendance at parenting classes must be pled. Section 61.21, Florida Statutes (2001), authorizes parenting courses....
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Alexander v. McCarthy, 752 So. 2d 1290 (Fla. 2d DCA 2000).

Published | Florida 2nd District Court of Appeal | 2000 Fla. App. LEXIS 3515, 2000 WL 299973

neither party met the residence requirements of section 61.021, Florida Statutes (1997). Although subject
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Rochester Southwell v. Mary Southwell (Fla. 2d DCA 2024).

Published | Florida 2nd District Court of Appeal

...The parties have one minor child, and the Former Husband argues that the trial court erred in not awarding timesharing to him when he had failed to complete a statutorily required parenting class. Because the Former Husband has not demonstrated reversible error, we affirm the final judgment. Section 61.21(4)(a), Florida Statutes (2021), mandates that each party to a dissolution of marriage proceeding that involves minor children "shall complete the Parent Education and Family Stabilization Course before the entry by the court of a final judgment." The statute requires a petitioner to "complete the course within 45 days after the filing of the petition." § 61.21(5). However, "[t]he court may excuse a party from attending the parenting course, or from completing the course within the required time, for good cause." § 61.21(4)(b). Each party must "file proof of compliance with this subsection with the court prior to the entry of the final judgment." § 61.21(5)....
...With respect to the failure of a party to comply, the statute provides that "[t]he court may hold any parent who fails to attend a required parenting course in contempt, or that parent may be denied shared parental responsibility or time-sharing or otherwise sanctioned as the court deems appropriate." § 61.21(9). It is undisputed that the Former Husband did not complete the required parenting course. The trial court awarded shared parental responsibility but denied timesharing to the Former Husband as section 61.21(9) allows....
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Smith v. Smith, 309 So. 2d 615 (Fla. Dist. Ct. App. 1975).

Published | District Court of Appeal of Florida | 1975 Fla. App. LEXIS 14449

residency in accordance with the provisions of F.S. § 61.-021. Our examination of the record reveals that there
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Gray v. Bresler, 82 So. 3d 821 (Fla. 5th DCA 2011).

Published | Florida 5th District Court of Appeal | 2011 WL 710160, 2011 Fla. App. LEXIS 2651

of the counterpetition, the requirements of section 61.021, Florida Statutes, were fulfilled.1 See Gilbert
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Loffler v. Loffler, 620 So. 2d 1048 (Fla. 5th DCA 1993).

Published | Florida 5th District Court of Appeal | 1993 Fla. App. LEXIS 6502, 1993 WL 210581

State, 549 So.2d 248 (Fla. 5th DCA 1989). Section 61.021, Florida Statutes (1989), provides that a dissolution
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Lemon v. Lemon, 314 So. 2d 623 (Fla. Dist. Ct. App. 1975).

Published | District Court of Appeal of Florida | 1975 Fla. App. LEXIS 13662

Florida have held that the residency requirement of § 61.021 F.S. and its predecessor is jurisdictional. Wade
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Clinton v. Carver, 675 So. 2d 642 (Fla. Dist. Ct. App. 1996).

Published | District Court of Appeal of Florida | 1996 Fla. App. LEXIS 6055, 1996 WL 310277

of the dissolution proceeding. For example, section 61.021 requires “one of the parties to the marriage”
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In re Amendment to Florida Rules of Civil Procedure Form 1.943(c), 563 So. 2d 1079 (Fla. 1990).

Published | Supreme Court of Florida | 15 Fla. L. Weekly Supp. 384, 1990 Fla. LEXIS 865, 1990 WL 94101

of the dissolution action. This is because section 61.021, Florida Statutes (1989), requires residence
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McNeil v. Jenkins-McNeil, 252 So. 3d 354 (Fla. 5th DCA 2018).

Published | Florida 5th District Court of Appeal

in the state before the filing of the petition. § 61.021, Fla. Stat. (2015). Residency for this statutory
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Fernandez v. Fernandez, 632 So. 2d 638 (Fla. Dist. Ct. App. 1994).

Published | District Court of Appeal of Florida | 1994 Fla. App. LEXIS 189, 1994 WL 16644

before the filing of a petition for dissolution. Section 61.021, Fla.Stat. (1991). Furthermore, evidence establishing
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Bowers v. Bowers, 326 So. 2d 172 (Fla. 1976).

Published | Supreme Court of Florida | 1976 Fla. LEXIS 4318

the residency requirement laid down by Fla.Stat. § 61.021 (1973). The circuit, court granted the motion
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Sutton v. Sutton, 705 So. 2d 1054 (Fla. 1st DCA 1998).

Published | Florida 1st District Court of Appeal | 1998 Fla. App. LEXIS 1203, 1998 WL 55976

meet the residency requirement set forth in section 61.021 of the Florida Statutes (1995).1 However, the
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Padilla v. Vindel, 132 So. 3d 378 (Fla. 4th DCA 2014).

Published | Florida 4th District Court of Appeal | 2014 Fla. App. LEXIS 1835, 2014 WL 537512

before the filing of the petition as required by section 61.021, Florida Statutes (2012). See Rudel v. Rudel
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Jacques Junior Armand v. Ginou Armand Amisy (Fla. 3d DCA 2021).

Published | Florida 3rd District Court of Appeal

Florida residency requirement pursuant to section 61.021, Florida Statutes. He claimed that he was
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Sragowicz v. Sragowicz, 591 So. 2d 1084 (Fla. Dist. Ct. App. 1991).

Published | District Court of Appeal of Florida | 1991 Fla. App. LEXIS 12895, 1991 WL 280141

Gillman, 413 So.2d 412, 413 (Fla. 4th DCA 1982); § 61.021, Fla.Stat. (1989). Affirmed.
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Rahal v. Zerhouni, 861 So. 2d 114 (Fla. 3d DCA 2003).

Published | Florida 3rd District Court of Appeal | 2003 Fla. App. LEXIS 19517, 2003 WL 23008976

residency requirement was satisfied in this case. See § 61.021, Fla. Stat. (2003). There is ample record support
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Grey v. Grey, 995 So. 2d 623 (Fla. 2d DCA 2008).

Published | Florida 2nd District Court of Appeal | 2008 Fla. App. LEXIS 18612, 2008 WL 5191670

evidence of residency in Florida. We reverse. Section 61.021, Florida Statutes (2007), provides that “[t]o
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Cleveland v. Cleveland, 692 So. 2d 304 (Fla. 5th DCA 1997).

Published | Florida 5th District Court of Appeal | 1997 Fla. App. LEXIS 4842, 1997 WL 213035

alleged and met the residence requirements of section 61.021,2 and the wife admitted that she received actual
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James P. Mejia v. Rosa B. Mejia (Fla. 4th DCA 2020).

Published | Florida 4th District Court of Appeal

“chief seat” of affairs was in Florida. Section 61.021, Florida Statutes, requires one of the parties
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Young-Maile v. Maile, 813 So. 2d 1077 (Fla. 4th DCA 2002).

Published | Florida 4th District Court of Appeal | 2002 Fla. App. LEXIS 5222, 2002 WL 662824

the petition for dissolution of marriage. See § 61.021, Fla. Stat. (1999)(to obtain a dissolution of
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Merritt v. Merritt, 369 So. 2d 1005 (Fla. Dist. Ct. App. 1979).

Published | District Court of Appeal of Florida | 1979 Fla. App. LEXIS 14417

by statute in Florida is that contained in Section 61.021, Florida Statutes (1977). Appellant met that
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O'Connor v. O'Connor, 357 So. 2d 763 (Fla. Dist. Ct. App. 1978).

Published | District Court of Appeal of Florida | 1978 Fla. App. LEXIS 15768

for six months before filing the action. See Section 61.021, Florida Statutes (1971). Fraud upon the court
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Fields v. Fields, 782 So. 2d 530 (Fla. 1st DCA 2001).

Published | Florida 1st District Court of Appeal | 2001 Fla. App. LEXIS 5052, 2001 WL 376683

marriage. The two appeals then were consolidated. Section 61.021, Florida Statutes (1997), states that “[t]o

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