UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
v.
ELIZABETH ARAGONES
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A trial court's application of a 2.0 contingency fee multiplier in a first-party property insurance dispute is supported by competent substantial evidence and does not constitute an abuse of discretion.
[1] In determining whether to apply a contingency fee multiplier to a lodestar amount, a trial court should consider whether the relevant market requires such a multiplier to…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“the primary rationale for the contingency risk multiplier is to provide access to competent counsel for those who could not otherwise afford it”
Bell v. U.S.B. Acquisition Co., 734 So. 2d 403, 411 (Fla. 1999), cited for the foundational purpose of contingency fee multipliers
Universal Property & Casualty Insurance Company appealed a trial court's order awarding prevailing party attorney's fees to insured Elizabeth Aragones…
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Third District Court of Appeal State of Florida
Opinion filed September 17, 2025. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D24-0488 Lower Tribunal No. 21-5914-CA-01 ________________
Universal Property & Casualty Insurance Company, Appellant,
vs.
Elizabeth Aragones, Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Beatrice Butchko Sanchez, Judge.
Link & Rockenbach, PA, and Kara Rockenbach Link and David A. Noel (West Palm Beach), for appellant.
Alvarez, Feltman, Da Silva & Costa, PL, and Paul B. Feltman, for appellee.
Before EMAS, GORDO and BOKOR, JJ.
PER CURIAM.
2 In this first-party property insurance dispute, Universal Property & Casualty Insurance Co. appeals the trial court’s order awarding prevailing party attorney’s fees to plaintiff/insured Elizabeth Aragones. The sole issue raised on appeal is whether the trial court’s inclusion of a 2.0 contingency fee multiplier in the attorney’s fee award was supported by competent substantial evidence. Upon our review, see Universal Prop. & Cas. Ins. Co. v. Medero, 406 So. 3d 323, 326 (Fla. 3d DCA 2025) (“Although a trial court’s determination to apply a multiplier to the lodestar amount is reviewed for an abuse of discretion, the trial court’s findings as to the multiplier itself must be supported by competent substantial evidence.”), we find there was competent substantial evidence to support the trial court’s factual determinations and no abuse of discretion in the trial court’s application of a 2.0 multiplier. See Standard Guar. Ins. Co. v. Quanstrom, 555 So. 2d 828, 834 (Fla. 1990) (reaffirming the relevant principles and holding that, in considering whether to apply a contingency fee multiplier, the trial court should consider the following factors: “(1) whether the relevant market requires a contingency fee multiplier to obtain competent counsel; (2) whether the attorney was able to mitigate the risk of nonpayment in any way; and (3) whether any of the factors set forth in Rowe are applicable,
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Standard Guar. Ins. Co. v. Quanstrom, 555 So. 2d 828 (Fla. 1990)
- Bell v. U.S.B. Acquisition Co., Inc., 734 So. 2d 403 (Fla. 1999)
- TRG Columbus Dev. Venture, Ltd. v. Sifontes, 163 So. 3d 548 (Fla. 3d DCA 2015)