Claudia Umana v. MRG Glazing Contractors, Inc.

Summary

The Third District Court of Appeal of Florida affirmed an attorney’s fee award in a final judgment of foreclosure of a construction lien. The court held that, because the appellant did not provide a transcript of the fee hearing, she failed to demonstrate reversible error regarding the requested fees and contingency fee multiplier.

Holdings

1. The appellate court affirmed the attorney's-fee award because Umana did not furnish a transcript of the fee hearing and therefore did not demonstrate reversible error.
2. An award of attorney's fees is reviewed for abuse of discretion.
3. Whether claims are inextricably intertwined is a question of law reviewed de novo.

Questions Presented

1. Whether the attorney's-fee award should be reversed because the amount of fees and use of a contingency-fee multiplier were allegedly unsupported by competent, substantial evidence when the appellant did not provide a transcript of the fee hearing.
2. What standards of review apply to an attorney's-fee award and to the determination whether claims are inextricably intertwined.

Disposition

affirmed