Sara Cristina Babun, etc., v. Stok Kon + Braverman, etc., et al.

Summary

The Third District Court of Appeal reversed an interim attorney's fee award in a probate and trust matter, holding that the trial court's failure to make specific findings on the reasonable number of hours, hourly rate, and any reduction or enhancement factors as required by *Florida Patient's Compensation Fund v. Rowe*, 472 So. 2d 1145 (Fla. 1985), is reversible error. The court emphasized that an award of attorney's fees without adequate findings justifying the amount cannot stand, and the record lacked competent substantial evidence to support the fee award; the case was remanded for a new hearing with proper *Rowe* findings.

Holdings

1. An award of attorney's fees without adequate findings justifying the amount is reversible error because the trial court must make specific findings as to the reasonable number of hours expended, the normal hourly rate, and any reduction or enhancement factors.

Questions Presented

1. Whether the trial court made sufficient findings under Florida Patient's Compensation Fund v. Rowe to support an award of interim attorney's fees and costs.

Disposition

reversed_and_remanded