Liran Zorella and Zorella Investments, LLC v. Pathman Schermer Tandy, LLP
The Third District affirmed a final judgment awarding a law firm compensatory damages against its former clients for breach of a written retainer agreement. The court rejected the clients' argument that the trial court was required to apply the Rowe lodestar framework before fixing the damages award, holding that Rowe governs fee awards imposed on a non-contracting payor, not contract damages for fees the client itself agreed to pay. The court alternatively noted the claim failed for lack of a trial transcript and failure to preserve the findings issue by a timely rehearing motion.
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