Supportive Relationships Under Florida Statute 61.14: Building the Factual Record

Practical brief for Florida family law attorneys and paralegals.

Section 61.14(1)(b), Florida Statutes, requires a court to reduce or terminate alimony on specific written findings that a supportive relationship has existed between the obligee and an unrelated person. The obligor carries the burden of proof, and the statute lists the factors the court must address in writing. Those factors are factual, and most of them can be documented with public records and lawful observation.

What the statute requires

Under the current version of section 61.14(1)(b), amended in 2023:

• The court must reduce or terminate support on specific written findings that a supportive relationship has existed between the obligee and a person not related by consanguinity or affinity.
• The obligor must prove, by a preponderance of the evidence, that a supportive relationship exists or existed in the 365 days before the filing of the petition. If proven, the burden shifts to the obligee to show why support should not be reduced or terminated.
• The court must make written findings on the factors in section 61.08(3) and the additional factors in section 61.14(1)(b)2.
• A conjugal relationship is not necessary for the statute to apply.

The factors, and the evidence that fits each one

• Holding out as a married couple. Use of the same last name, a common mailing address, references to each other as husband or wife. Evidence: public social media posts, public event listings, public records showing shared addresses.
• Period of time residing together. Evidence: dated observations over a meaningful period of overnight stays and morning departures, vehicles regularly parked at the residence, addresses on licenses, registrations, filings and court records.
• Pooled assets or income, joint accounts, financial interdependence. Evidence: jointly titled real property or vehicles in public records. Bank details come through discovery, not through the investigator.
• Financial support of one by the other, including paying debts. Evidence: often discovery, supported by public records showing who owns and who lives in the home.
• Valuable services for each other, or for the other’s business. Evidence: observed household and business activity in public view, Sunbiz filings listing the obligee in a role in the partner’s company, public business pages.
• Working together to acquire or improve assets, and joint purchases. Evidence: deeds, permits, vessel or vehicle registrations and entity filings that show joint ownership or projects.
• Agreements about property sharing or support. Usually a discovery and deposition question; observations can help counsel frame it.
• Support for each other’s children or family members. Evidence: observations in public settings such as school pickups or family events, handled with care for the children’s privacy.

How the field work is done

Supportive relationship cases are won on patterns, not single sightings. We plan observation windows around the questions that matter, such as overnight stays across several weeks, and log each one with date, time, location and photos taken from public places. The goal is a record a judge can follow, which also supports any later cohabitation surveillance report or testimony.

The legal lines

• Public vantage points only. No trespass, no entering homes, no photographing into private spaces where people have a reasonable expectation of privacy.
• No recording of private conversations. Florida’s Chapter 934 requires all-party consent.
• No access to private accounts. We capture public social media only. Requesting access to the obligee’s private accounts would raise Bar rule issues for counsel.
• No contact with a represented party. Rule 4-4.2 applies to investigators working for a lawyer.

Records first, then observation

Most assignments start with records: property, vehicles, entities, court filings and public social media for both the obligee and the other person. That research often shows whether the relationship looks long-term and where to focus field time, which keeps cost proportional. It also overlaps with our work on hidden assets in Florida divorces and social media evidence.

Working with MAYN Investigations

MAYN Investigations is a Florida private investigation agency licensed under Chapter 493 (agency license A3400126). We support family law investigations for attorneys in Orlando, Melbourne, Lakeland and across Florida, with reports written for written findings and testimony when needed.

FAQ: supportive relationship investigations

Do we have to prove a romantic relationship?

No. Section 61.14(1)(b)3 says a conjugal relationship is not necessary. The focus is financial and economic support equivalent to a marriage.

How long should observation run?

Long enough to show a pattern across the statutory factors. We recommend windows based on what records show, rather than open-ended daily coverage.

Can you testify?

Yes. The investigator who made the observations can testify about what was observed, supported by the dated log and photographs.

What do you need to start?

The final judgment and alimony terms, the obligee’s address, anything known about the other person, vehicles, and the time frame that matters for the petition.

This article is general information for attorneys and legal professionals. It is not legal advice, and decisions about discovery, admissibility and compliance belong to counsel.