Fourth District, Division One So Rules In Unpublished Decision.
In Marriage of Breen, Case No. D062502 (4th Dist., Div. 1 Dec. 2, 2013) (unpublished), the appellate court affirmed a family law judge’s setting of spousal support for ex-wife and awarding needs-based fees to her also. On appeal, husband argued that the lower court did not go through all of the needs-based factors in making rulings. The appellate court rebuffed this argument by noting that husband cited no case or other authority establishing that every factor had to be cited on the record in order to validate needs-based awards.