Citizens Property Insurance Corporation v. Meghan Anderson

Summary

The Florida Second District Court of Appeal reversed an attorneys' fee award to Meghan Anderson that included a 1.7 contingent fee multiplier. The court held that the trial court's order lacked a specific finding on whether the relevant market required a multiplier under Florida fee-award precedent, and that the absence of a hearing transcript did not preclude reversal because the error was apparent on the face of the order. The case was remanded for further proceedings.

Holdings

1. A trial court awarding a contingency fee multiplier must make specific findings addressing the applicable enhancement factors, including whether the relevant market required a multiplier to obtain competent counsel. A conclusory statement that the case was appropriate for a multiplier is insufficient.
2. The absence of a transcript does not preclude reversal when the fee order is fundamentally erroneous on its face because it lacks findings required by Rowe and Quanstrom.

Questions Presented

1. Whether the trial court erred by applying a 1.7 contingency fee multiplier without making a specific finding that the relevant market required the multiplier.
2. Whether the absence of a transcript or adequate substitute statement of the fee hearing precluded appellate reversal of the fee award.

Disposition

reversed_and_remanded