Background
Citizens Property Insurance Corporation appealed a final judgment from Miami-Dade County Court awarding attorney’s fees and costs to Quality Mold Finders Corporation in the amount of $12,025.00. The trial court based its award on section 57.105(1), Florida Statutes (2025), which permits recovery of attorney’s fees when a party asserts a claim or defense that is not supported by material facts or applicable law. Citizens challenged the award on appeal, contending the trial court failed to comply with statutory requirements for such awards.
The Court’s Holding
The Third District Court of Appeal reversed the trial court’s fee award. The court held that the trial court failed to make the specific findings necessary to support an award under section 57.105(1). Notably, the trial court did not render findings that Citizens’ affirmative defense “when initially presented to the court or at any time before trial: (a) Was not supported by the material facts necessary to establish the claim or defense; or (b) Would not be supported by the application of then-existing law to those material facts.”
The court emphasized, citing prior precedent, that section 57.105 requires the trial court to make specific findings of bad faith and recite the facts supporting its conclusions. A conclusory or unsupported award of attorney’s fees is insufficient to withstand appellate review.
Key Takeaways
- Trial courts must make explicit, factual findings when awarding attorney’s fees under section 57.105(1)—conclusory awards will be reversed.
- The trial court must determine whether the challenged claim or defense lacked support in either material facts or applicable law at the time it was presented.
- Defendants asserting affirmative defenses have procedural protection: fee awards require documented judicial reasoning, not stipulated amounts absent proper findings.
- Appellate courts will reverse fee awards that lack the specific statutory predicates, even if the parties have stipulated to the amount.
Why It Matters
This decision reinforces strict procedural requirements for attorney’s fees awards under section 57.105(1) in Florida. Trial courts cannot simply accept stipulated fee amounts without undertaking the mandated analysis. For defendants and insurers facing fee requests, this ruling ensures that parties claiming fees must persuade the court through specific findings about the weakness of the opposing party’s position—not merely through settlement or agreement.
The decision also provides appellate protection against fee awards that lack proper factual and legal support. Trial courts must document their reasoning carefully or risk reversal, which benefits litigants who contest the reasonableness or statutory basis for such awards.