National Insurance USA Group LLC v. MAPP Digital US, LLC
A defendant served a $1 offer of judgment that expressly stated it included the plaintiff's attorney's fees and costs; the plaintiff accepted and final judgment was entered for $1 'inclusive of Plaintiff's court costs and attorney's fees.' The trial court initially granted the defendant's section 57.105(7) reciprocal fee motion but on rehearing denied it, finding the parties intended the plaintiff to be the prevailing party. The Fourth DCA reversed, holding the offer and judgment resolved only the plaintiff's fee claim and did not bar the defendant from seeking its own fees under section 57.105(7).
Key facts
- National Insurance USA Group LLC (plaintiff) sued MAPP Digital US, LLC (defendant); the defendant served a $1 offer of judgment expressly stating it included plaintiff's attorney's fees and costs.
- Plaintiff accepted the offer and final judgment was entered for $1 'inclusive of Plaintiff's court costs and attorney's fees.'
- +2 more key facts with a free trial
Why it matters
Practitioners drafting or accepting offers of judgment should note that language making the offer 'inclusive of' the offeree's fees and costs resolves only the offeree's fee claim and does not extinguish the offeror's… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.