Coates v. R.J. Reynolds Tobacco Co.
After the Florida Supreme Court approved the Fifth DCA's decision reversing a $16 million punitive damages award as excessive, the plaintiff moved for appellate attorney's fees based on R.J. Reynolds's rejection of her pretrial proposals for settlement. The Court held that section 768.79 is not a prevailing-party statute, so a movant need not prevail in the appellate proceeding to recover fees, and provisionally granted the fee motion subject to the trial court's entitlement and amount determinations.
Key facts
- Plaintiff Coates obtained a $16 million punitive damages award against R.J. Reynolds Tobacco Company at trial, which the Fifth District Court of Appeal reversed as excessive.
- After the Florida Supreme Court approved the Fifth DCA's reversal, Coates moved for appellate attorney's fees under section 768.79 based on R.J. Reynolds's rejection of her pretrial settlement proposals.
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Why it matters
This resolves a recurring dispute over whether a proposal-for-settlement movant must prevail on appeal to recover appellate fees, answering no and opening the door to fee awards for parties who lose the appeal but hold… — full analysis with a trial
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