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Chair's Message

"For every door that's been opened to me, I've tried to open my door to others." - Michelle Obama

 

Happy July, and Happy New Bar Year! 

 

I am so honored to be writing to you as Chair of the Family Law Section of The Florida Bar. I was installed on June 17, 2026, surrounded by people I love and colleagues I deeply respect, and I have been smiling ever since. I am excited for what lies ahead. 

 

This Section has meant the world to me. I started my legal career as an FFLA Civil Legal Aid Summer Fellow in 2000, joined the Legal Aid Society of the Orange County Bar Association, Inc. in 2001, and have spent the past 25 years advocating for Florida's families through legal aid. Serving as your Chair is an honor I will never take for granted. 

 

I want to thank my entire team at the Legal Aid Society of the Orange County Bar Association, Inc., for supporting me through every year of my service on this Section's Executive Committee. Showing up for Section leadership takes time and energy, and they never once made me feel that it was anything other than time well spent. That kind of support is a gift, and I am grateful for it. 

 

A heartfelt thank you to Immediate Past Chair Aimee Gross for an outstanding year of "Supporting Today, Reshaping Tomorrow." Aimee, your leadership, vision, and dedication have left a lasting mark on this Section, and I am grateful for the example you have set. Thank you also to Chair-Elect Andrea N. Reid, Treasurer Michelle Klinger Smith, Secretary Trisha P. Armstrong, and Section Administrator Willie Mae Shepherd, whose grace, professionalism, and tireless dedication keep this Section running smoothly every day. 

 

And a special acknowledgment to our newest Trustee, Chris Rumbold. Chris has long been a trusted advisor, valued friend, and steadfast supporter of this Section. His guidance, insight, and institutional knowledge are invaluable, and I am delighted to have him serving in this important role. 

 

Now, let's talk about this year. 

 

This year's theme is simple: Empower. Elevate. Excel. 

 

To empower means giving all members the tools, connections, and confidence to serve Florida's families at the highest level. To elevate means lifting up the voices and perspectives that make this Section stronger. To excel means holding ourselves to the standard this Section has always set, and then raising it a little higher. 

 

There is so much ahead of us, and I want you to be part of it. Whether you are a longtime Section leader or someone who has been thinking about getting more involved, this is your year. There is a committee, an event, or an opportunity with your name on it. 

 

Get Involved | Attend an Event | Become a Sponsor

 

Our first major event is the Leadership Retreat at Sunseeker Resort in Charlotte Harbor, August 26-30, under the theme "Rise and Lead: Your Next Chapter Starts Here." 

 

If you have ever thought about stepping into a leadership role in this Section, this retreat is the place to start. The program is outstanding, the setting is beautiful, and the relationships you build there can last a lifetime. I would love to see you there. 

 

Thank you for welcoming me into this role. Every door this Section has opened for me, I intend to open wider for someone else. That is my commitment to you, and I look forward to a year of empowering, elevating, and excelling together. 

 

Tenesia C. Hall, Esq. 

Chair, 2026-2027 

2026 Leadership Retreat & Fall Meetings - ROOM BLOCK SOLD OUT

Registration is still open and the hotel does have rooms available, however, our room block is now sold out. But, we'd still love to see you at our upcoming Leadership Retreat and Fall Meetings, Aug. 26-29 at the Sunseeker Resort Florida Gulf Coast!

Level up in Family through our two tracks - 'Leadership in the Section' and 'Leadership in the Profession' - an engaging series that supports our retreat theme, 'Rise and Lead: Your Next Chapter Starts Here.' Hear from The Florida Bar President, Michael Orr, as well as members of the judiciary and board-certified family law attorneys.


The Section is offering seven scholarship opportunities to attend the Retreat! The deadline to apply is Friday, July 17 at 5 p.m. EDT.

2026-27 Section Calendar

August

26-30

2026 Leadership Retreat & Fall Meetings - Sunseeker Resort Forida Gulf Coast - ROOM BLOCK SOLD OUT

October

14-17

Out-of-State Retreat - The Royal Sonesta, New Orleans, LA


January

20-23

Marital & Family Law Review Course and Mid-Year Meetings - Gaylord Palms, Orlando. (Registration opens in September.)


February

18-19

Live CLE: Inside the Guardian ad Litem Role: Practical Skills for GALs and What Attorneys Need to Know. The Dalmar, Fort Lauderdale. More info coming soon!


March

18-21

In-State Retreat: Three Waters Resort and Marina, Islamorada. More info coming soon!


LEVEL UP!

From the Publications Committee Co-Chairs, Michael Mendoza and Jennifer Kipke


As our Chair, Tenesia Hall, has shared above, this year’s theme for the 2026-2027 Bar Cycle is Empower. Elevate. Excel. In line with this theme, we are excited to announce a new series that will bring together voices from across the Section each month to share experiences, tips, and tools that will inspire us to bring our practice to the next level.


Each month, the “Level Up” series will feature contributions from a diverse cross-section of our membership, including seasoned practitioners, emerging attorneys, and Section leaders who have navigated the evolving demands of legal practice with distinction. These submissions will draw from real-world experience and practical insight, offering readers an authentic look at the strategies and perspectives that have shaped successful careers within our professional community.


Readers can expect content that spans a broad range of topics relevant to today’s legal professional - from business development and client relations - to wellness, leadership, and the effective use of emerging technologies in practice. Each featured piece has been selected not only for the quality of its insight, but for its ability to speak directly to the challenges and opportunities our members encounter in their day-to-day work.


At its core, the “Level Up” series is a living expression of what Empower. Elevate. Excel. means in practice. To empower is to equip ourselves and one another with the knowledge and confidence to lead. To elevate is to raise the standard of our work and our presence in the profession. To excel is to pursue, with intention, the highest version of what our practice can be. This series is designed to support each of those goals, one month at a time. We hope you will find it as valuable as we intend it to be, and we warmly invite you to consider contributing your own voice to a future edition.

Case Law Update

By Mark F. Baseman, Esq.

Ehiabor v. Ehiabor, 2026 WL 1676200 (Fla. 1st DCA June 10, 2026).


In 2024, the First DCA caused minor panic among family law attorneys with Haslauer v. Haslauer, 381 So. 3d 662, in which the majority wrote that section 61.16, Florida Statutes, permitted only “prospective” attorney’s fees awards “rather than . . . retrospective” awards. Id. at 666. In other words, Haslauer suggested that neither section 61.16 nor its paternity counterpart, section 742.045, allowed trial courts to reimburse a party for fees incurred earlier in the litigation. Id. While the court’s ultimate holding did not rely on this point of law, Judge Tanenbaum authored a concurring opinion pointedly disavowing the notion that section 61.16 permitted fees awards “after the fact.” Id. at 669. Judge Tanenbaum concluded that the statute’s purpose was merely to ensure that both spouses had counsel during the litigation. Thus, if a party was represented throughout the litigation, “how could there still be a need” for fees once the case was over? Id. at 672. Judge Tanenbaum added that section 61.16 prohibited reimbursement even if a party paid for her attorney on “credit.” Id.

Haslauer’s holding, read with Judge Tanenbaum’s concurrence, led many to conclude that retrospective fee awards were impermissible in the First District despite a history of case law suggesting otherwise. Perhaps worse, practitioners outside the First District were left guessing as to whether Haslauer represented the first opinion that directly addressed this question, and, therefore, whether Haslauer was binding on trial judges outside the district.

Thankfully, the First DCA recently issued Ehiabor v. Ehiabor, 2026 WL 1676200 (Fla. 1st DCA June 10, 2026), where it seemingly retreated from some of Haslauer’s harsher implications.


Ehiabor involved the appeal of an order that, in pertinent part, awarded the wife temporary attorney’s fees. See id. at *1. Although the husband primarily argued that the order lacked the requisite findings, the district court took the opportunity to clarify that, in its view, section 61.16 was “broad enough” to permit both prospective and “retrospective” fee awards,” at least in situations where the “need for fees did not arise” until later in the litigation. Id. at *7. The court added in a footnote that it “decline[d] to follow” Judge Tanenbaum’s commentary in Haslauer, writing that a party who retains counsel on “credit” still has a need for financial assistance. Id. at *11, n.2.

So, where are we left post-Ehiabor? In this author’s view, trial courts (at least those outside the First DCA) should feel comfortable continuing to award fees retroactively since there is no clear precedent from any district precluding such awards. Ideally, the legislature will clarify the law soon; in the meantime, trial judges should follow the precedent from their districts when considering whether to award fees in divorce and paternity cases. 

Tech Tip: E3 Toolbox 

From the Publications Committee

With this Bar Cycle, we are especially committed to equipping our readers with the tips, tools, and resources necessary to empower their professional growth, elevate the quality of their practices, and excel at every level of service they provide. Readers can expect topics spanning the strategic use of AI and emerging technology to streamline and strengthen day-to-day operations, as well as innovative approaches to better serve and support Florida’s families.


For family law practitioners looking to sharpen their competitive edge, one resource deserves a prominent place in your professional toolkit: LegalFuel, The Florida Bar’s Practice Resource Center. Offered entirely free of charge to Florida Bar members, LegalFuel is a comprehensive, one-stop destination designed to help attorneys run more efficient, better-managed practices - without adding to the billable-hour burden.


What makes LegalFuel particularly valuable for family law attorneys is the breadth of its offerings. Its dedicated technology page presents a curated library of articles and continuing legal education programming focused squarely on the legal industry. From navigating cybersecurity threats and evaluating the latest case management software, to understanding how artificial intelligence can streamline document review and client communications, the technology resources are both practical and immediately applicable to the demands of a busy family law practice. Whether you are a solo practitioner or part of a larger firm, these tools can help you work smarter, reduce administrative overhead, and deliver better outcomes for the families you serve.


Beyond technology, LegalFuel offers more than 100 hours of on-demand CLE webinars - available with no registration required - along with practice management guidance on trust accounting, firm finances, and operational best practices. The platform reflects The Florida Bar’s longstanding recognition that running a law firm requires business acumen alongside legal expertise.


We encourage every member of the Family Law Section to explore what LegalFuel has to offer. Start with the technology resource page and discover tools that can make a real difference in your practice today:


Sponsor Spotlight

Jason Soman, Soman Forensic & Valuation CPAs


1. Tell us about your company and the services you provide to family law attorneys and their clients.


At Soman Forensic & Valuation CPAs, our job is to help attorneys and their clients make better financial decisions during divorce.


We specialize in financially complex family law matters involving business valuation, income determination, tracing, equitable distribution, tax issues, and expert testimony. More importantly, we help determine which financial issues are likely to matter and which probably won't so attorneys and clients can focus their time and resources where they'll have the greatest impact.


2. What sets your company apart, or what's something about your services that family law practitioners might not know to ask about?


Communication and Judgment.


Our clients and referral attorneys always know where their case stands, what we're working on, and what comes next.


Just as importantly, we continually evaluate whether additional work is likely to create meaningful value. Sometimes the best advice we can give is that an issue simply isn't likely to materially affect the outcome of the case.


3. What trends are you seeing in your industry that family law attorneys should be paying attention to?


Beyond AI, I think the profession is becoming more focused on proportionality.


I've seen clients spend years and hundreds of thousands of dollars litigating financial issues that ultimately had very little impact on the outcome of their case.


The best attorneys and experts are increasingly asking a different question:

"Will resolving this issue materially change the economics of the case?"


That mindset leads to better outcomes because it keeps everyone focused on the issues that truly matter.


4. What do you wish more family law attorneys understood about working with financial planners/investment managers versus forensic accountants?



Financial planners and investment managers aren't trying to answer the same questions as forensic accountants. On the right cases, having both professionals involved can be highly complementary.


A forensic accountant determines the financial facts that affect the outcome of the divorce. A financial planner helps clients understand what those facts mean for their financial future.



I've seen financial planners play an instrumental role in helping clients become comfortable with settlement options because they could finally visualize life after the divorce. That perspective can be invaluable and often helps move difficult cases toward resolution.

Annual Sponsors

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PLATINUM SPONSOR

BRONZE SPONSORS

Interested in writing an article for FAMSEG or our quarterly magazine, The Commentator? Email publications@familylawfla.org for more info!


Interested in becoming an Annual or Event Sponsor? Email sponsorship@familylawfla.org for more info!

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