Louis J. Mank v. Marsha M. Mank

Divorce: Enforcement of judgment: Attorney’s fees
CSA No. 0330, Sept. Term 2013. Unreported.
Opinion by Nazarian, J. Filed Sept. 4, 2014.
Appeal from Baltimore County. Vacated and remanded.
RecordFax #14-0904-00, 25 pages.

In enforcing what was essentially a consent judgment, the lower court erred by ordering the husband to take steps beyond the scope of the parties’ agreement, and in awarding attorneys’ fees to the wife without indicating that it had considered the financial resources and needs of the parties and whether there was substantial justification for prosecuting or defending the proceeding as required by FL § 7-107(c).

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