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husband had died and the dissolution action had abated). We
believe a court would retain jurisdiction over an order to
enforce an award of attorney’s fees, even if Ms. Devers had died
prior to petitioner’s payment, and the court in the first
dissolution proceeding did not lose its authority to make the
order simply because the case did not result in a final marital
dissolution.
In Johnson v. Johnson, 894 S.W.2d 245, 247 (Mo. Ct. App.
1995), the court wrote that an “order on a PDL * * * is a final
judgment disposing of the merits from which an appeal may be
taken. * * * Such orders are in no way dependent on the merits
of the underlying dissolution suit.” Though that case concerned
a PDL award of maintenance, the same court found in an earlier
case that the principle applied to attorney’s fees. See Carlson
v. Aubuchon, 669 S.W.2d 294, 297 (Mo. Ct. App. 1984). In fact,
“It is well established in Missouri that orders on motions to
allow * * * suit costs pendente lite are judgments in independent
proceedings. They stand upon their own merits and are in no way
dependent on the merits of the underlying dissolution suit.”
Dardick v. Dardick, 661 S.W.2d 538, 540 (Mo. Ct. App. 1983); see
also Noll v. Noll, 286 S.W.2d 58, 62 (Mo. Ct. App. 1956).
Whether or not the case giving rise to the PDL ordering the
payment at issue ever culminated in an Order of Dissolution, the
award of attorney’s fees to Mr. Dubin was made on its own merits
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