Foot & Ankle Center of Florida, LLC v. Carlos Vargas, IV
After winning summary judgment on FCCPA and declaratory relief claims, Vargas obtained a fee award enhanced by a 1.5 contingency fee multiplier. The Sixth DCA reversed the multiplier because the fee movant presented no competent, substantial evidence on the first Quanstrom factor — whether the relevant market required a multiplier to obtain competent counsel — and remanded solely for entry of a judgment without the multiplier, denying a second evidentiary hearing.
Key facts
- Foot & Ankle Center of Florida won summary judgment against Carlos Vargas on FCCPA and declaratory relief claims in the trial court.
- After winning, Vargas obtained a fee award that included a 1.5 contingency fee multiplier based on expert testimony that multipliers incentivize attorneys to take difficult cases and that the client could not afford hourly rates.
- +2 more key facts with a free trial
Why it matters
This is a clean Sixth DCA statement adopting the strict Joyce/Quanstrom relevant-market evidentiary requirement and, importantly, refusing to remand for a do-over. Defense counsel opposing multipliers in statutory fee… — full analysis with a trial
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