RM & Associates Consulting, Inc., a/a/o Quame McKinnon v. People's Trust Insurance Company
The Fourth DCA reversed the appellate attorney's fee portion of a fees judgment because the award rested on conclusory expert testimony rather than competent substantial evidence of reasonably necessary hours. The court emphasized that fee testimony must do more than characterize litigation as complex and must account for overlap with parallel litigation involving materially similar issues.
Key facts
- RM performed water-remediation work under an assignment of benefits and sued People's Trust for the unpaid balance.
- People's Trust prevailed on summary judgment, which was affirmed on appeal, and obtained a conditional appellate fee award under section 768.79.
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Holdings
- An attorney's fee award under the lodestar method must be supported by competent substantial evidence demonstrating the specific hours were reasonably necessary; conclusory testimony about…
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Why it matters
This opinion is a useful tool for parties challenging inflated appellate fee awards, confirming that block-billed 'answer brief' entries and generalized expert testimony will not sustain a lodestar award, and that… — full analysis with a trial
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