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According to Florida case law as of the date of this article, lump sum alimony is not subject to modification:

“Lump sum alimony vests at the time of entry of the final judgment and is not subject to modification. Philipose v. Philipose, 431 So.2d 698 (Fla. 2d DCA 1983); Horne v. Horne, 289 So.2d 39 (Fla. 2d DCA 1974). Therefore, the trial judge erred when he modified the final judgment to grant the wife a one-half interest in the pension and profit sharing plan rather than the original lump sum of $64,000.00.”

See: Miller v. Miller – 455 So.2d 436 (1984)




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