Florida Form CR2E034 is the Final Judgment of Dissolution of Marriage with Property but No Dependent or Minor Child(ren), and you fill it out by entering the case caption, identifying both spouses, listing all marital and nonmarital assets and debts, attaching the signed Marital Settlement Agreement, and presenting it to the judge for signature at the final hearing. This form ends the marriage, divides property, and creates an enforceable court order under Florida Statutes Chapter 61.
The form looks short, but every blank line carries legal weight. A wrong checkbox or a missing asset can leave you stuck in court for years, force you to refile, or even cost you property you thought you had secured. According to the Florida Department of Health Vital Statistics, Florida records roughly 70,000 dissolutions of marriage each year, and a large share involve property division without minor children — the exact scenario CR2E034 is built for.
Here is what you will learn in this guide:
- 📋 How to complete every line, box, and signature block on Form CR2E034 the right way
- ⚖️ Why each section exists under Florida law and what happens if you skip it
- 🏠 How to properly divide a home, retirement account, vehicles, and joint debts
- 🚫 The seven biggest mistakes filers make and how to avoid losing property because of them
- 🧾 Real named examples, three popular scenarios, and ten plain-English FAQs
What Florida Form CR2E034 Is and When You Use It
Florida Form CR2E034 is a Florida Supreme Court Approved Family Law Form used as the proposed Final Judgment in a divorce where the spouses own property together (or separately) but have no dependent or minor children. The judge signs this form at the end of the case to officially end the marriage and divide property.
You use this form when three conditions match your situation. First, you and your spouse must have property, debts, or both to divide. Second, you must have no minor or dependent children together. Third, you must be filing under Florida law, which requires that at least one spouse has lived in Florida for six months before filing, as set by Florida Statutes § 61.021.
The form is part of a larger packet that begins with the Petition for Dissolution of Marriage with Property but No Dependent or Minor Child(ren), which carries the form number 12.901(b)(2). CR2E034 is not the petition. It is the final judgment — the order the judge signs to close the case.
The Legal Foundation Behind the Form
The form exists because Florida law requires every divorce to end with a written final judgment. Florida Family Law Rule of Procedure 12.490 and Rule 1.510 confirm that judges cannot enter a verbal divorce — they must sign a document that lists exactly what the court decides.
The plain-English explanation is that CR2E034 turns your agreement (or the judge’s ruling after trial) into an enforceable court order. The consequence of skipping or botching it is severe: without a signed final judgment, you are still legally married, even if you think the case is over. A real-world example is Maria, who walked out of a hearing believing her divorce was final, only to discover two years later — when she tried to remarry — that the judge had never signed her CR2E034 because the property list was blank.
A common misconception is that the Marital Settlement Agreement alone ends the marriage. It does not. Only the signed Final Judgment ends a Florida marriage under Florida Statutes § 61.052.
Who Should File CR2E034 vs. a Different Form
Choosing the wrong final judgment form is one of the most expensive mistakes a pro se filer makes. Florida publishes three closely related forms, and they are not interchangeable. Filing the wrong one can force you to start your case over, pay another $409 filing fee, and wait months for a new hearing.
The core difference between the three forms is whether you have property and whether you have minor children together. Each form maps to a specific statute and a specific petition. Pick the one that matches your facts, not the one that looks easiest.
| Form Number | When You Use It | Key Statute Anchor |
|---|---|---|
| CR2E033 (12.990(a)) | No property, no children — see Form 12.990(a) | § 61.052 |
| CR2E034 (12.990(b)) | Property to divide, no minor children | § 61.075 |
| CR2E035 (12.990(c)) | Property and minor or dependent children — see Form 12.990(c)(1) | § 61.13 |
Step-by-Step: How to Fill Out Every Section of CR2E034
The form has seven major sections, and each one ties back to a specific Florida statute. You must complete every section that applies to your case. Leaving a section blank when it applies is the same as asking the judge to deny your divorce.
The structure mirrors the Florida Family Law Rules of Procedure 12.285 mandatory disclosure rules. That rule requires both spouses to share full financial information before the judge will sign anything. The consequence of hiding an asset is that the court can reopen the case years later and award that asset to your spouse under Macar v. Macar, 803 So. 2d 707 (Fla. 2001).
Section 1: The Case Caption
The caption is the box at the top of page one. You write the Florida circuit court name (for example, In the Circuit Court of the Eleventh Judicial Circuit, Miami-Dade County), the case number assigned by the clerk, and the division (usually Family).
You also list the Petitioner (the spouse who filed first) and the Respondent (the other spouse). The names must match the original Petition exactly. If the Petition says Robert James Smith but you write Bob Smith on CR2E034, the clerk may reject the filing.
The consequence of a wrong caption is delay. James, a filer in Hillsborough County, lost three weeks because he wrote the wrong division on his form, and the clerk routed it to the civil division instead of family.
Section 2: Findings of Fact
This section asks the judge to confirm three jurisdictional facts. The first is that one spouse lived in Florida for at least six months before filing, as required by § 61.021. The second is that the marriage is irretrievably broken, the no-fault standard set by § 61.052(2). The third is that the court has personal jurisdiction over both spouses.
You check the boxes that apply. If your spouse lives out of state, you must also confirm that they were properly served under Florida Statutes § 48.193, the long-arm statute. The consequence of skipping the long-arm finding is that your judgment can be voided later for lack of jurisdiction.
A common misconception is that you can claim irretrievably broken without your spouse’s agreement. You can. Florida is a pure no-fault state, and one spouse’s testimony is enough under the rule confirmed in Burger v. Burger, 166 So. 2d 433.
Section 3: Dissolution of the Marriage
This is the one-line paragraph that says, The marriage between the parties is dissolved. It looks like boilerplate, but it is the operative sentence of the entire form. Without it, nothing else matters.
You do not fill in any blanks here. You simply leave the language as printed. The judge’s signature on the last page activates this paragraph and ends the marriage on the date of signing.
The consequence of altering this paragraph is that the clerk may refuse to record the judgment. Carmen, a filer in Orange County, crossed out the word dissolved and wrote annulled — the judge struck the entire form and made her start over with the correct annulment paperwork.
Section 4: Division of Marital Assets and Liabilities
This is the longest and most consequential section. You must list every marital asset and every marital debt, then state who gets what. The legal framework is equitable distribution under § 61.075, which presumes a 50/50 split but allows the judge to deviate based on factors like contribution, duration of the marriage, and economic circumstances.
You list assets first. Real estate goes by full legal description, not just street address. Vehicles go by VIN, year, make, and model. Bank accounts go by institution name and the last four digits of the account number — never the full number, per Florida Rule of Judicial Administration 2.425 on minimization of personal information.
You then list debts in the same way. Each debt names the creditor, the last four digits of the account, the balance, and the spouse who will pay it. The consequence of leaving a debt off is that both spouses remain jointly liable to the creditor, even if the judgment says otherwise — the judgment binds the spouses but not the bank, as confirmed in Gibson v. Bennett, 561 So. 2d 565 (Fla. 1990).
A real-world example is David, who forgot to list a $14,000 joint credit card. His ex-wife stopped paying it, the bank sued both of them, and David’s wages were garnished even though the judgment said his ex was responsible. He had to file a separate enforcement action under § 61.14 to recover his money.
Section 5: Spousal Support (Alimony)
If alimony applies, you check the appropriate box and attach the terms. Florida recognizes several types of alimony under § 61.08, as overhauled by the 2023 alimony reform law (SB 1416).
The four current types are bridge-the-gap, rehabilitative, durational, and temporary. Permanent alimony was eliminated for cases filed after July 1, 2023. The form asks you to specify the type, amount, duration, and start date.
The consequence of vague alimony language is that it becomes unenforceable. Linda’s judgment said her ex-husband would pay her what is fair — a phrase the appellate court in Canakaris v. Canakaris, 382 So. 2d 1197 (Fla. 1980) made clear is too vague to enforce. She had to relitigate the entire alimony question.
Section 6: Former Name Restoration
Florida law lets either spouse restore a former name at no extra cost as part of the divorce. You check the box, write the exact prior name, and the judge’s signature makes the change official under § 61.041.
If you skip this box and decide later to change your name, you must file a separate civil name change petition under Chapter 68. That costs another $400 in filing fees and requires a fingerprint background check.
A common misconception is that name restoration is automatic. It is not. The judge cannot restore a name that is not requested in the form.
Section 7: Reservation of Jurisdiction and Signature
The final section says the court reserves jurisdiction to enforce the judgment. This single sentence is what lets you go back to the same judge if your ex stops paying alimony or refuses to deed the house.
You leave the date and signature lines blank for the judge. You sign the Petitioner or Respondent line below, and your spouse signs theirs. Both signatures must be notarized or signed in front of a deputy clerk under § 117.05.
The consequence of skipping the reservation language is that you may have to file a brand-new lawsuit to enforce the judgment, which costs more and takes longer.
Three Popular Scenarios With CR2E034
Real cases rarely look like the form’s blank template. The three scenarios below show how filers in different situations actually complete the form.
Scenario 1: The Jointly-Owned Home
| Filer Action | Court Outcome |
|---|---|
| Sarah and Tom list their Tampa home with full legal description, mortgage balance, and a clause that Tom refinances within 90 days | Judge signs CR2E034, Tom refinances, Sarah signs a quitclaim deed and is removed from the mortgage |
| Sarah and Tom write only the house with no address or refinance deadline | Judge refuses to sign, sends them back to redraft under § 61.075(3) |
Scenario 2: Retirement Accounts and a QDRO
| Filer Action | Court Outcome |
|---|---|
| Marcus and Jennifer list Marcus’s 401(k) by plan name and last four digits, with a Qualified Domestic Relations Order attached | Plan administrator splits the account tax-free under IRC § 414(p) |
| Marcus and Jennifer write split the 401(k) 50/50 with no QDRO | Marcus withdraws funds to pay Jennifer, triggers a 10% penalty plus full income tax |
Scenario 3: Default Judgment After No Response
| Filer Action | Court Outcome |
|---|---|
| Elena serves her husband, waits 20 days, then files a Motion for Default and CR2E034 with full property list | Judge signs default judgment under Rule 12.140, Elena keeps the property she requested |
| Elena files CR2E034 without first getting a clerk’s default | Judge refuses to sign — no default means no authority to grant relief without a hearing |
Concrete Named Examples
Robert Alvarez, a 52-year-old contractor in Jacksonville, used CR2E034 to end a 20-year marriage. He listed his pickup truck, his wife’s sedan, a joint savings account, and a $38,000 home equity line. Because he attached a clear Marital Settlement Agreement, the judge signed the form at an uncontested hearing in under 10 minutes.
Priya Shah, a 34-year-old nurse in Fort Lauderdale, filed CR2E034 after a four-year marriage with no children. She used the name-restoration box to return to Shah from her married name Patel. Because she filled out the box correctly, she avoided a separate $400 name change filing.
Greg Thompson, a 61-year-old retiree in Naples, filed CR2E034 after a 28-year marriage. He listed his pension, a beach condo, and three vehicles. He missed the QDRO step, and his pension administrator refused to honor the divorce order. He paid a family-law attorney $2,500 to draft a separate QDRO under ERISA § 206(d) — a cost he could have avoided by attaching the QDRO to CR2E034.
Mistakes to Avoid When Filing CR2E034
Each mistake below has triggered real cases of denied judgments, lost property, or expensive do-overs.
- Listing assets without identifying details leads to unenforceable orders because the sheriff cannot levy on the boat without a hull number under § 56.061.
- Forgetting the Family Law Financial Affidavit required by Rule 12.285 causes the judge to cancel the final hearing.
- Skipping the notary block voids the spouses’ signatures under § 117.05 and forces a refile.
- Mixing marital and nonmarital property can give your spouse half of an inheritance that should have stayed yours under § 61.075(6)(b).
- Omitting the reservation-of-jurisdiction clause forces a brand-new lawsuit if your ex breaks the deal, doubling your costs.
- Using the wrong form number (filing CR2E033 when you have property, or CR2E035 when you have no children) results in clerk rejection.
- Failing to attach the Marital Settlement Agreement referenced in the form leaves the judge with nothing to incorporate and the order unenforceable.
- Writing vague alimony language like reasonable support invalidates the alimony award under Canakaris.
- Leaving out joint debts keeps you on the hook to creditors regardless of what the judgment says.
- Not appearing at the final hearing when required leads to dismissal under Rule 12.420.
Dos and Don’ts for CR2E034
Do
- Do attach a complete Marital Settlement Agreement because the judgment incorporates the MSA word for word and an incomplete MSA creates an incomplete judgment.
- Do bring two extra copies to the final hearing so the judge keeps one, the clerk keeps one, and you walk out with a conformed copy.
- Do verify the § 61.021 residency with a Florida driver’s license issued at least six months before filing because the judge will ask under oath.
- Do double-check VINs, account numbers, and legal descriptions against the source documents to prevent typos that void enforcement.
- Do request name restoration in the form itself to avoid a separate $400 Chapter 68 filing later.
Don’t
- Don’t sign the form before the notary or deputy clerk because predated signatures invalidate the document under § 117.05.
- Don’t list the full Social Security or full account number because Rule 2.425 requires only the last four digits.
- Don’t write to be determined in any blank because the judgment must be final and certain to be enforceable.
- Don’t use white-out or cross-outs because the clerk treats altered originals as defective and rejects them.
- Don’t forget the Notice of Social Security Number required by § 61.052(7) before the judge will sign.
Pros and Cons of Using CR2E034
Pros
- Standardized format approved by the Florida Supreme Court means judges across all 67 counties accept the same form.
- Free download from the Florida Courts website saves the cost of attorney drafting for simple cases.
- Built-in name restoration under § 61.041 saves a separate $400 filing fee.
- Reservation of jurisdiction lets the same judge enforce the order under § 61.14 without a new lawsuit.
- Compatible with simplified dissolution when both spouses agree, which lets the case finish in 30 days.
Cons
- One-size-fits-all language does not handle complex assets like business interests, which require custom drafting under Thompson v. Thompson, 576 So. 2d 826.
- No automatic QDRO means retirement-account splits need a separate order under ERISA § 206(d).
- No tax guidance built into the form leaves filers exposed to surprise liabilities under IRC § 1041.
- Notarization requirement under § 117.05 adds a step that simplified out-of-state forms skip.
- Strict caption rules under Rule 12.080 cause clerk rejection for minor typos that other states ignore.
Federal Law Layer: What Floridians Must Also Know
Although CR2E034 is a state form, federal law shapes several of its sections. The Internal Revenue Code § 1041 treats most property transfers between divorcing spouses as nontaxable, but only if the transfer happens within one year of the divorce or is incident to the divorce. Sloppy CR2E034 language can blow that window and trigger capital-gains tax.
ERISA § 206(d) governs the division of private retirement plans and demands a QDRO that meets specific federal standards. State courts can order a 401(k) split, but only a QDRO accepted by the plan administrator actually moves the money. The U.S. Department of Labor QDRO guide walks through the federal requirements.
The Servicemembers Civil Relief Act protects active-duty military spouses from default judgments. If your spouse is on active duty, you must file the SCRA Affidavit before the judge will sign CR2E034.
Key Florida Court Rulings That Shape CR2E034
Canakaris v. Canakaris set the reasonableness standard for alimony and equitable distribution and remains the most-cited family-law case in Florida. Vague language in CR2E034 collapses under Canakaris.
Rosen v. Rosen, 696 So. 2d 697 (Fla. 1997) governs attorney’s fees in dissolution and confirms that the judgment can order one spouse to pay the other’s fees if there is a need-and-ability gap.
Macar v. Macar lets a court reopen a divorce judgment when one spouse hides an asset, which is the consequence of leaving an item off CR2E034’s property list.
Step-by-Step Filing Process
- Complete the Petition (Form 12.901(b)(2)) and pay the $409 filing fee at the clerk’s office.
- Serve your spouse through the sheriff or a private process server under Chapter 48.
- Wait 20 days for a response. If none, file a Motion for Default.
- Exchange mandatory disclosure under Rule 12.285 within 45 days.
- Sign a Marital Settlement Agreement before a notary.
- Draft CR2E034 and bring it to the final hearing for the judge’s signature.
- File the signed judgment and request a certified copy from the clerk of court.
FAQs
Is CR2E034 the same as the Marital Settlement Agreement?
No. CR2E034 is the final judgment signed by the judge. The Marital Settlement Agreement is the spouses’ contract that the judgment incorporates and enforces.
Can I file CR2E034 without a lawyer?
Yes. Florida explicitly allows pro se filing through its Family Law Self-Help Center. Most uncontested CR2E034 cases finish without an attorney.
Do both spouses have to sign CR2E034?
Yes, in uncontested cases, but in default cases only the petitioner signs because the respondent failed to answer within 20 days under Rule 12.140.
Does CR2E034 work if we have minor children?
No. Use Form CR2E035 (12.990(c)(1)) instead because it includes the parenting plan and child-support sections required by § 61.13.
Can I include alimony in CR2E034?
Yes. Section 5 of the form has a built-in alimony block under § 61.08, updated by the 2023 reform law.
How long after filing does CR2E034 get signed?
No firm timeline exists, but uncontested cases average 30 to 90 days, while contested cases under Rule 12.200 can take 12 months or more.
Does CR2E034 restore my maiden name automatically?
No. You must check the name-restoration box and write the exact prior name under § 61.041, or you will need a separate Chapter 68 petition.
Can the judge change CR2E034 after signing?
Yes, but only under Rule 1.540 for fraud, mistake, or newly discovered evidence, generally within one year of entry.
Does CR2E034 divide a 401(k) by itself?
No. You also need a Qualified Domestic Relations Order under ERISA § 206(d) for the plan administrator to honor the split.
Can I appeal CR2E034 if I disagree with it?
Yes. You have 30 days from the date of signing to file a notice of appeal with the Florida District Court of Appeal under Rule 9.110.
Related reading
- How to Fill Out Florida Form 12.901(b)(2) (w/Examples) + FAQs
- How to Fill Out Florida Form 12.902(f)(1) (w/Examples) + FAQs
- How to Fill Out Florida Form 12.990(a) (w/Examples) + FAQs
- How to Fill Out Florida Form 12.990(b)(1) (w/Examples) + FAQs
- How to Fill Out Florida Form 12.990(b)(2) (w/Examples) + FAQs
- How to Fill Out Florida Form 12.990(c)(1) (w/Examples) + FAQs
- How to Fill Out Florida Form 12.930(d) (w/Examples) + FAQs