Can Florida courts enforce a Canadian divorce decree?

Deegan v. Taylor, 28 So.3d 227 (Fla. 2nd DCA 2010), the trial court enforced the Canadian divorce degree despite subsequent litigation.

WHERE CANADIAN DIVORCE DECREE AWARDED ALIMONY TO WIFE AND PARTIES RESOLVED A SUBSEQUENT ENFORCEMENT ACTION THROUGH A SETTLEMENT AGREEMENT WHICH PROVIDED FOR PREVAILING PARTY ATTORNEY'S FEES IN ANY FUTURE ENFORCEMENT ACTION, CANADIAN COURT'S SUBSEQUENT GRANT OF ANNULMENT BUT DETERMINATION THAT BECAUSE OF THE PARTIES' SIX-YEAR PUTATIVE MARRIAGE, THE PARTIES "SHALL BENEFIT FROM THE EFFECT OF THE JUDGMENT OF DIVORCE," TRIAL COURT ERRED IN DENYING WIFE ATTORNEY'S FEES WHEN IT FOUND HUSBAND IN CONTEMPT FOR NON-PAYMENT OF ALIMONY. 

The trial court found the former husband in contempt for non-payment of alimony, set a purge amount, and entered a money judgment in the former wife's favor for the arrears. The trial court, however, denied former wife's request for prevailing party attorney's fees, reasoning the provision entitling her to prevailing party attorney's fees in the parties' 2004 settlement agreement did not apply because it had been based on the premise of a valid marriage. The District Court reversed:

1. "The request for fees does not require us to explore the equitable principles apparently at play in [an earlier case]. Rather, the real issue is the deference owed to the Canadian decree."

2. "In handling [the Wife's] motion for contempt and enforcement, the trial court was called upon to enforce a domesticated Canadian decree that specifically retained all accessory measures, despite the grant of annulment. Accordingly, [the Wife] is entitled to prevailing party attorney's fees as an accessory measure that survived the annulment of her marriage to [the Husband]."