Certain Underwriters at Lloyd's London v. Candelaria
After a jury awarded insureds $52,000 in a Hurricane Irma first-party property case, the trial court awarded over $600,000 in fees and costs using an arbitrary 15% across-the-board reduction of billed hours plus a 1.8 contingency multiplier. The Third DCA reversed, holding the lodestar lacked competent substantial evidence because neither the insureds' expert nor the court made line-item, particularized findings, and the multiplier failed because no evidence addressed whether counsel could mitigate the risk of nonpayment (i.e., whether the clients could afford a retainer or hourly fees). The court directed entry of a fee award based on 480.5 hours—the defense expert's line-by-line figure—with no multiplier.
Key facts
- Insureds sued their insurer after Hurricane Irma property damage; a jury awarded $52,000 in the first-party insurance case.
- At the fee-and-costs hearing, the trial court awarded over $600,000 in attorney's fees using a 15% across-the-board reduction of billed hours plus a 1.8 contingency multiplier, without specific findings on individual time entries.
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Why it matters
This is a strong defense-side tool in first-party property fee litigation: it extends Deshpande and Casanas beyond small, quickly-settled cases to heavily litigated, tried cases, confirming that 'blanket percentage'… — full analysis with a trial
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