## Facts

- Robert S. Young (father) and Alice G. Hector (mother) married in 1982 and had two daughters (born 1985 and 1988).
- Hector, an attorney, obtained high-paying employment in Miami and moved there with the children in 1989; Young remained in New Mexico temporarily to finish projects and sell the family home.
- Young later spent extended periods away from Miami for business ventures, including about fourteen months in New Mexico in 1992–1993; the children stayed with Hector and visited Young regularly.
- The family used paid household help (e.g., nanny, au pair, or housekeeper) to assist with childcare.
- Hector’s income rose substantially (eventually exceeding $300,000 annually) after she accepted a shareholder position at a large law firm; Young’s business fortunes declined after the 1987 stock-market crash.
- The parties separated while residing in the marital home; Hector filed for dissolution in 1995.
- A guardian ad litem recommended Hector as primary residential parent based on her economic stability, her consistent presence in the children’s lives, and concern about Young’s temper.
- Young argued he had become the primary day-to-day caretaker in the years immediately preceding dissolution and claimed the custody ruling reflected gender bias.

## Issues

1. Whether the trial court abused its discretion or relied on impermissible gender stereotypes in designating Hector as the primary residential parent under the best-interests standard.
2. Whether the trial court erred in its determinations regarding rehabilitative alimony, equitable distribution of assets and liabilities, and attorney’s fees.

## Decision

- On rehearing en banc, the appellate court affirmed the designation of Hector as primary residential parent.
- The court held the custody determination was supported by substantial competent evidence and did not reflect gender bias.
- The court reversed the rulings on rehabilitative alimony, equitable distribution, and attorney’s fees and remanded those financial issues for further proceedings.

## Legal Principles

- Trial courts have broad discretion in child-custody determinations; appellate review is limited and will not disturb custody findings supported by substantial competent evidence.
- Florida custody determinations turn on the child’s best interests; no single factor (including a claimed “primary caretaker” role) is dispositive.
- Allegations of gender bias in custody awards require record support; reliance on evidence-based, gender-neutral factors such as stability, continuity, and parental fitness does not constitute impermissible stereotyping.
- Financial awards in dissolution cases (alimony, equitable distribution, and fees) must be grounded in proper application of governing standards and supported by the evidentiary record; errors require remand for reconsideration.

## Conclusion

The en banc court upheld the mother’s primary residential custody designation because the record supported a best-interests finding centered on stability and continuity, while sending the parties back to the trial court to reexamine alimony, equitable distribution, and attorney’s fees.


Young v. Hector, 740 So. 2d 1153 (Fla. 3d DCA 1998)