CBRE, Inc. v. DidierGroup, LLC
Following the 6th DCA's March 2026 reversal of the underlying final judgment in CBRE v. DidierGroup (No. 6D2023-3011), the court automatically reversed the predicate attorney fee and costs judgment. Standard rule: an attorney fee award predicated on a reversed or vacated final judgment must itself be reversed, without prejudice to renewed fee proceedings at the conclusion of the case.
Key facts
- CBRE, Inc. appealed a final judgment for attorney's fees and costs that the Orange County Circuit Court had entered in favor of DidierGroup, LLC, predicated on CBRE losing the underlying commercial real estate brokerage dispute.
- The underlying final judgment on which the fee award was based had been separately appealed in case No. 6D2023-3011, and the Sixth DCA reversed that underlying judgment in its March 13, 2026 opinion.
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Holdings
- An award of attorney's fees and costs predicated on a reversed or vacated final judgment must also be reversed. Citing Jupiter Mall Realty Corp. v. Rosner's, Inc., 614 So. 2d 52, 52 (Fla…
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Why it matters
Textbook application of the derivative fee-award rule in commercial real estate brokerage litigation. Practitioners seeking or defending fee awards should anticipate that a reversal on the merits wipes out any predicate… — full analysis with a trial
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