Columbus574, LLC v. Susan Deppert
The Fourth DCA reversed on all three issues raised. It held a contingency fee multiplier was improper because no contingency fee agreement existed and no showing was made that a multiplier was needed to obtain competent counsel; it reversed the award of mortgage interest because the buyer never secured a mortgage; and it reversed and remanded the interest award to clarify whether the court intended pre- or post-judgment interest.
Key facts
- Deppert sued Columbus574, LLC for specific performance of a residential sales contract for a St. Lucie County home and obtained a judgment for specific performance after a non-jury trial.
- After prior appeals resolved the transfer of the residence, the circuit court awarded Deppert $138,850.32 in supplemental damages (including mortgage interest, rents, insurance, and interest) and a 2.0 contingency fee multiplier adding $320,620.00 in attorney's fees.
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Holdings
- A contingency fee multiplier requires, at a minimum, the pre-existence of a contingency fee agreement, plus a showing under Rowe and Quanstrom that a multiplier was needed to obtain…
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Why it matters
The decision is notable for confirming that a contingency fee multiplier cannot be awarded without an actual contingency fee agreement, a threshold point that defeats multiplier claims regardless of the 2023 amendments… — full analysis with a trial
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