Summary
The Florida Third District Court of Appeal affirmed the county court's ruling in an appeal involving an award of costs and attorney's fees. The court explained that pro se non-attorneys are not entitled to attorney's fees and that various attorney and administrative expenses are not recoverable as taxable costs.
Holdings
- The trial court's ruling was affirmed; the appellate court found no basis to grant relief on the issues concerning costs and attorney's fees.
- A non-attorney proceeding pro se is not entitled to an award of attorney's fees.
Questions Presented
- Whether the trial court properly resolved the issues concerning the award of taxable costs and attorney's fees.
- What standard of review applies to a trial court's cost award and to legal questions concerning the availability and classification of costs.
- Whether non-attorneys proceeding pro se may recover attorney's fees.
Disposition
affirmed
Cases Cited (7)
- Cornfeld v. Plaza of the Americas Club, Inc., 306 So. 3d 1136, 1139 (Fla. 3d DCA 2020)(followed)
- Lee v. Animal Aid, Inc., 388 So. 3d 25, 31 (Fla. 4th DCA 2024)(followed)
- Kay v. Ehrler, 499 U.S. 432, 435 (1991)(followed)
- Schultheis v. Schultheis, No. 3D23-1250, 2026 WL 516519, at *1 (Fla. 3d DCA Feb. 25, 2026)(followed)
- Short v. State, 579 So. 2d 163, 164 (Fla. 2d DCA 1991)(followed)
- Flopro v. EOX Tech. Sol., Inc., FLOPRO, LLC v. EOX Tech. Sols., Inc., 375 So. 3d 904, 905 (Fla. 4th DCA 2023)(followed)
- Centex-Rooney Construction Co., Inc. v. Martin County, 725 So. 2d 1255, 1261 (Fla. 4th DCA 1999)(followed)
Cited In (0)
No citing cases on record yet.
Court Document
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