If you’re going through a divorce in the Tampa Bay area and you have children, there’s a good chance child support is one of the things keeping you up at night. Will the number be fair? Will it actually reflect what you and your co-parent earn? What happens if the judge gets it wrong? These are exactly the kinds of questions a Tampa divorce lawyer hears every week, and they’re exactly the questions raised by a recent decision out of Florida’s Third District Court of Appeal, Izquierdo v. Iglesias, 427 So. 3d 1181 (Fla. 3d DCA 2026).
This case is a useful one to talk about — not because it’s dramatic or unusual, but because it’s the opposite. It’s a reminder that even in routine divorce cases, trial courts sometimes issue final judgments that don’t line up with Florida’s child support guidelines, and that when they do, the person on the losing end of that math has a right to ask an appellate court to fix it. If you’re currently negotiating a parenting plan, a marital settlement agreement, or heading toward a final hearing in Hillsborough County, this case is worth understanding — and it’s exactly the type of issue an experienced Tampa divorce lawyer watches for before a judgment is ever entered.
Below, we’ll walk through what happened in Izquierdo, why the appellate court stepped in, and — most importantly — what it means for your own case if you’re navigating divorce or child support in Florida right now. We’ll keep the legal jargon to a minimum, because you shouldn’t need a law degree to understand what happens to your own family’s finances.
What Is Izquierdo v. Iglesias? A Plain-English Case Summary
Izquierdo v. Iglesias was decided by Florida’s Third District Court of Appeal in 2026. The case reached the appellate court after a trial court entered a final judgment in a family law matter that included a child support determination. On appeal, the panel — with Judge Ivonne Cuesta writing for the court — reviewed that final judgment and found that, at least in part, it conflicted with Florida’s statutory child support guidelines.
The result: the Third DCA affirmed the trial court’s ruling in part, but reversed it in part specifically as to the child support determination, sending that portion of the case back to the trial court to be corrected so that it aligns with the guidelines.
If that sounds a little abstract, here’s the plain-English version: a Florida trial judge signed off on a final divorce judgment, and part of what that judgment ordered for child support didn’t match what the law actually requires. The parent who was on the wrong end of that mismatch appealed, and the appellate court agreed that the number needed to be recalculated. The rest of the judgment — the parts that didn’t involve this guidelines conflict — was left standing.
This is what’s known in legal practice as an “affirmed in part, reversed in part” outcome, and it’s actually a fairly common result in family law appeals. Trial courts handle enormous caseloads and make dozens of factual and legal findings in a single final judgment. It doesn’t take a serious error, or any bad intent from the judge, family law is simply detailed and numbers-driven, and if one calculation slips out of alignment with the statutory formula, it’s grounds for a partial reversal, even while everything else in the judgment stands.
Why This Case Matters Even Though the Facts Are Narrow
We want to be upfront about something: appellate decisions like this one are often reported in brief form, focused on the legal holding rather than a lengthy narrative of the underlying facts. What we know for certain from the published record is the core legal takeaway: a final judgment’s child support terms conflicted with the guidelines, and the Third DCA corrected that on appeal. We’re not going to speculate about the specific incomes, parenting schedule, or personal circumstances of the parties in this case, because that information isn’t something we’re going to guess at.
What we can say with confidence is this: the case illustrates a principle that comes up again and again in Florida family law, and it’s one that every parent going through a divorce in Tampa, Brandon, Riverview, or anywhere else in Hillsborough County should understand. Florida’s child support guidelines aren’t just a suggestion. They’re a statutory formula, and a final judgment that departs from that formula without proper justification is vulnerable to reversal on appeal.
What the Court Decided — and Why It Matters for Florida Families
To understand why Izquierdo matters, it helps to understand how Florida calculates child support in the first place, and why courts don’t have unlimited freedom to deviate from that formula.
Florida’s Child Support Guidelines, in Plain Terms
Florida Statute § 61.30 sets out the state’s child support guidelines. At a high level, the formula looks at:
- Both parents’ net (after-tax) monthly incomes
- The combined income of both parents
- The number of overnights each parent has with the children (timesharing)
- Costs like health insurance premiums for the children and daycare or after-school care
- The number of children involved
The statute includes a guidelines chart that translates combined parental income into a baseline total support obligation, which is then divided between the parents based on their proportional share of income and, in many cases, adjusted further depending on the timesharing schedule.
This isn’t a system where a judge simply picks a number that feels fair. It’s a formula-driven calculation, and Florida law requires that a final judgment either follow that calculation or explain, with specific written findings, why deviating from it is justified in a particular case. A judge can deviate from the guideline amount, Florida law allows for that in certain circumstances, but a deviation has to be supported by findings that meet the statutory standard. A guideline amount that’s simply miscalculated, or a final judgment that orders a support figure without grounding it in the statutory worksheet, is a different problem entirely, and it’s the kind of problem that gets reversed on appeal.
Why Appellate Courts Take This Seriously
Florida’s appellate courts, including the Third District, have consistently held that child support determinations need to be tethered to the guidelines and supported by the record. This isn’t the court being a stickler for paperwork. Child support orders determine how a family’s income is split to support their children, sometimes for well over a decade. A miscalculation isn’t a minor clerical issue; it can mean hundreds or even thousands of dollars a year flowing in the wrong direction, year after year, until someone catches it and corrects it.
That’s exactly what the reversal in Izquierdo v. Iglesias represents. The appellate court didn’t rewrite Florida family law or create some new legal test. It simply held the trial court’s judgment accountable to the guidelines that already exist, and sent the child support piece back to be fixed. The rest of the final judgment, the parts that weren’t in conflict with the guidelines, was affirmed and left intact.
For parents, the significance isn’t really about legal doctrine. It’s about the reassurance that the guidelines exist for a reason, and that Florida’s court system has a built-in mechanism, appellate review, to catch it when a final child support order strays from what the statute actually requires.
The “Affirmed in Part, Reversed in Part” Outcome Explained
If you’re reading appellate case law in connection with your own divorce, you’ll come across this phrase often: “affirmed in part, reversed in part.” It simply means the appellate court agreed with some portions of the trial court’s ruling and disagreed with others. It’s worth knowing this phrase because it tells you something important: appeals in family law cases are rarely all-or-nothing. A parent who appeals a final judgment isn’t necessarily asking the appellate court to throw out the entire divorce decree. Often, as appears to be the case here, the appeal is narrowly focused on one piece of the judgment that doesn’t hold up, while everything else, property division, timesharing, the rest of the parenting plan, stands as decided.
This matters because it shapes expectations. If your final judgment has one component that seems off, whether that’s the child support figure, an alimony calculation, or a distribution of a marital asset, it doesn’t necessarily mean the whole case needs to be relitigated. It may mean a targeted appeal or a motion to correct a specific portion of the order is the more realistic and cost-effective path.
Practical Takeaways for Anyone Going Through a Divorce in Florida
So what should you actually do with this information if you’re currently going through, or about to start, a divorce in the Tampa Bay area? Here are the practical lessons.
1. Insist on Seeing the Child Support Worksheet — Not Just the Final Number
Florida law requires a completed child support guidelines worksheet to accompany most final judgments involving minor children. That worksheet shows exactly how the number was calculated: both parents’ incomes, the timesharing adjustment, health insurance and childcare costs, and how the total obligation was divided. Don’t just accept a bottom-line dollar figure in a proposed judgment or marital settlement agreement. Ask to see the worksheet, and if the math doesn’t add up, or if a deviation from the guideline amount isn’t explained in writing, that’s worth raising before the judgment is finalized rather than after.
2. Understand That Deviations From the Guidelines Require Justification
If your case involves a support figure that’s above or below the strict guideline calculation, that’s not automatically a problem. Florida law permits deviations of up to five percent without specific written findings, and larger deviations are allowed when supported by statutory factors, such as extraordinary medical expenses, independent income of the child, or a significantly disproportionate timesharing arrangement. But those deviations need to be documented and justified in the judgment itself. A support order that departs from the guidelines without that explanation is exactly the kind of issue that led to the reversal in Izquierdo.
3. Review Your Final Judgment Carefully Before It’s Entered
Many family law cases in Hillsborough County settle through a marital settlement agreement, and the final judgment often incorporates that agreement. Once a judgment is entered, correcting a math error or a guidelines conflict typically requires either a motion for rehearing (filed quickly, within strict deadlines) or a formal appeal, both of which take time, cost money, and add stress to a process you’re hoping to put behind you. It’s far better to catch a discrepancy while the case is still pending, when your attorney can raise it with opposing counsel or the court directly.
4. Know That Appeals Exist for a Reason, and They Work
If you’re on the receiving end of a final judgment that you believe conflicts with the child support guidelines, know that Florida’s appellate courts do take these issues seriously, as Izquierdo itself demonstrates. That doesn’t mean every disagreement with a judge’s decision is grounds for reversal; appellate courts generally defer to a trial judge’s factual findings and won’t second-guess reasonable exercises of discretion. But when a final judgment’s numbers genuinely conflict with the statutory guidelines, rather than simply reflecting a discretionary call you disagree with, that’s a different category of issue, and it’s one appellate courts are willing to correct.
5. Work With Someone Who Reviews the Numbers, Not Just the Narrative
Divorce cases often focus heavily on the emotional and relational parts of the process, and understandably so. But child support is, at its core, a math problem governed by a statute. A Florida divorce attorney who takes the time to run the guidelines worksheet independently, rather than simply accepting the figure presented by opposing counsel or even a mediator, is doing important, protective work on your behalf. This is true whether you’re the parent who will be paying support or the parent who will be receiving it; both sides benefit from a correctly calculated number.
6. Remember That Modification Is Also an Option
If you’re not currently in the middle of a divorce, but you have an existing child support order that you believe was calculated incorrectly, or that no longer reflects your or your co-parent’s current income, Florida law also allows for modification of child support when there’s been a substantial change in circumstances. This is a separate legal process from an appeal, and it’s worth discussing with a Tampa family law attorney if your financial situation, or your co-parent’s, has changed significantly since your original order was entered.
Marital Asset Division and the Bigger Financial Picture
While Izquierdo is specifically about child support, it’s a good reminder that final judgments in Florida divorce cases involve several interlocking financial calculations, child support, alimony, and marital asset division, all of which need to be grounded in the correct application of Florida law. An error in one area doesn’t necessarily mean the whole judgment is flawed, but it does mean the entire document deserves careful review before it’s finalized. Whether you’re dividing a home in South Tampa, retirement accounts, or a small business, precision matters, and the same statutory rigor that applies to child support calculations applies across the board.
This is one of the reasons divorce cases benefit from experienced legal guidance rather than a do-it-yourself approach, even when a case seems amicable. It’s not about assuming bad faith on the other side. It’s about making sure the final numbers, on support, on property, on everything, are actually correct before you sign off on an agreement you’ll be living with for years.
Why This Matters If You’re Facing Divorce in Hillsborough County
If you’re currently navigating a Hillsborough County divorce, whether you’re just starting the process or you’re staring down a final hearing date, cases like Izquierdo v. Iglesias are a useful reminder that the details matter. Florida’s child support guidelines exist to create consistency and fairness, and when a final judgment departs from them without justification, the law provides a path to correct it. But that path, appeal or post-judgment motion, is far more difficult and costly to walk after the fact than it is to get the calculation right from the start.
This is exactly where working with a knowledgeable Tampa divorce lawyer makes a real difference. An attorney who understands Florida’s guidelines inside and out can review your proposed settlement or final judgment before you agree to it, catch a miscalculation before it becomes a permanent part of your case, and, if necessary, pursue a correction or appeal on your behalf.
You Don’t Have to Navigate This Alone
Divorce is stressful enough without wondering whether the numbers in your final judgment actually reflect what Florida law requires. Whether you’re just beginning the process, in the middle of negotiations, or reviewing a judgment you suspect may not be right, the team at The McKinney Law Group is here to help. Our attorneys understand Florida’s child support guidelines, marital asset division rules, and family law procedure, and we’re committed to making sure the outcome of your case is both accurate and fair.
If you’re searching for a Tampa divorce lawyer who will take the time to review every number in your case, not just the headline terms, we encourage you to reach out. A brief consultation with The McKinney Law Group can help you understand where you stand, what to watch for, and how to protect your family’s financial future. You’ve got enough to manage right now; let us handle the legal details.
Frequently Asked Questions
1. What does “affirmed in part, reversed in part” mean in a Florida divorce case? It means the appellate court agreed with some portions of the trial court’s final judgment and disagreed with others. Only the reversed portion goes back to the trial court to be corrected; the rest of the judgment stays in place.
2. Can a Florida judge deviate from the child support guidelines? Yes, but only within limits. Deviations of five percent or less from the guideline amount don’t require specific written findings, but anything beyond that generally needs to be justified in writing based on factors recognized by Florida Statute § 61.30, such as extraordinary expenses or a unique timesharing arrangement.
3. What should I do if I think my child support order doesn’t match the guidelines? Start by asking for the child support guidelines worksheet used to calculate the order. If the numbers don’t line up and there’s no written explanation for a deviation, speak with a Florida family law attorney about whether a motion for rehearing, an appeal, or a modification action is the appropriate next step, depending on your timeline.
4. How long do I have to appeal a final judgment in a Florida divorce case? Generally, a notice of appeal must be filed within 30 days of the final judgment being entered. This deadline is strict, so if you believe your judgment contains an error, it’s important to consult an attorney promptly.
5. Is child support based only on income, or are other factors involved? Income is central to the calculation, but Florida’s guidelines also factor in the number of overnights each parent has with the children, health insurance premiums for the children, and childcare costs, among other statutory adjustments.
6. Do I need a lawyer if my divorce is uncontested? Even in an uncontested or amicable divorce, it’s worth having an attorney review your settlement agreement and proposed final judgment. Calculation errors, including child support miscalculations like the one at issue in Izquierdo v. Iglesias, can happen even when both parties are cooperating, and they can be much harder to fix after the judgment is entered.
7. What’s the difference between an appeal and a modification of child support? An appeal challenges an error in how the original judgment was decided and must generally be filed within 30 days. A modification is a separate legal action available later, when there’s been a substantial, material, and typically involuntary change in circumstances since the order was entered, such as a significant change in either parent’s income.
This article is provided for general informational purposes and does not constitute legal advice. Every family law case involves unique facts, and outcomes depend on the specific circumstances involved. If you have questions about your own divorce or child support case, contact The McKinney Law Group to discuss your situation with an attorney.
Damien McKinney is the Founding Partner of The McKinney Law Group Family & Divorce Lawyers, bringing nearly two decades of experience to complex marital and family law matters. He is licensed in both Florida and North Carolina and has been repeatedly recognized as a Rising Star by Super Lawyers.