In January 2026, Florida’s Third District Court of Appeal issued a decision that should be required reading for anyone negotiating—or trying to undo—a marital settlement agreement: Paniry v. Paniry, Case No. 3D25-2107.

The opinion is not flashy, but it is important. It draws a firm line between legitimate fraud claims and post-judgment fishing expeditions, and it reinforces a principle Florida courts take seriously: final judgments, especially in family law, are not easily reopened.

The Background: A Deal Made, Then Questioned

David and Dawn Paniry resolved their divorce through a negotiated marital settlement agreement. The trial court entered an agreed final judgment in September 2023.

Seven months later, Dawn moved to vacate that judgment. Her claim: David had misrepresented his income. Specifically, she argued that he failed to update his financial affidavit after receiving a promotion—from assistant CFO at one hospital to CFO at another.

Based on that allegation, the trial court allowed limited post-judgment financial discovery.

David sought certiorari relief, arguing that Dawn’s allegations were conclusory and legally insufficient to justify reopening discovery after a final judgment.

The Third District agreed—and quashed the discovery order.

Florida’s Policy: Finality Is Not a Technicality

The appellate court began with a principle that experienced family lawyers know well: Florida strongly favors the finality of judgments, particularly in dissolution cases.

Yes, Florida law allows a court to set aside a final judgment based on fraud. But that exception is narrow, and it comes with real requirements.

A party seeking to reopen a settled case must first allege—and ultimately prove—the elements of fraud. That includes reliance. It is not enough to point to an omission or an inconsistency after the fact.

Why Alleging “He Made More Money” Wasn’t Enough

Dawn’s motion relied primarily on an article noting David’s new job title. It did not contain evidence that his income actually increased, much less by how much.

More importantly, the record showed something fatal to her claim: at the final hearing before the judgment was entered, Dawn told the court that David’s financial disclosures were incorrect and called the issue a “deal breaker.”

Yet she proceeded to sign the settlement anyway.

That matters. Fraud requires reliance on false information. If a party knows—or believes—that the information is false and still agrees to the deal, the reliance element collapses.

Florida courts have consistently rejected attempts to undo settlement agreements under these circumstances. You cannot knowingly accept a deal and later claim you were tricked.

Discovery Does Not Come First

One of the most significant aspects of Paniry is its reaffirmation of sequencing.

The trial court must first decide whether the allegations, on their face, establish a prima facie case of fraud. Only if that threshold is met does discovery come into play.

Even then, the court must consider whether the moving party could have discovered the information through reasonable diligence before signing the agreement.

Allowing discovery first—especially in post-judgment family law cases—turns finality on its head. The Third District made clear that this approach is improper.

Why This Case Matters Beyond Family Law

Although Paniry arises from a divorce, its lessons extend far beyond family court.

Negotiated settlements—whether in divorce, business disputes, or complex civil litigation—depend on finality. If conclusory allegations were enough to reopen discovery months or years later, settlement would lose much of its value.

The decision reinforces that courts will protect agreements reached with eyes open. Claims of fraud must be specific, credible, and legally sufficient before the machinery of post-judgment discovery is allowed to restart.

The Practical Takeaway

For clients, the message is straightforward: settlements matter, and so does the moment you sign them. If you believe information is wrong, that issue must be addressed before final judgment—or immediately through proper post-judgment procedures.

For lawyers, Paniry is a reminder that post-judgment discovery is not automatic, and that certiorari remains a powerful tool when trial courts allow cases to reopen without the necessary legal foundation.

Final judgments are meant to end disputes—not invite second chances based on speculation. Florida’s appellate courts continue to enforce that principle with care and consistency.

And cases like Paniry show exactly how—and why—they do it.