3003 INDIAN CREEK RR, LLC
v.
ALFREDO ARIAS

Fla. 3d DCA | 2023-04-19
No. 22-0721
Florida District Court of Appeal, Third District (2023)

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Holding

A motion for attorney's fees must be filed within thirty days of entry of final judgment unless the judgment itself determines entitlement to attorney's fees.


Headnotes

[1] A motion for attorney's fees must be filed within thirty days of entry of final judgment unless the judgment itself reserves or determines the prevailing party's entitlem…

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Key Quotes

“A motion for attorney's fees must be filed within thirty days of entry of final judgment to permit a trial court to award such fees. The only recognized exception to this requirement is when the trial court has already, in the judgment, determined entitlement to attorney's fees as part of the relief granted to the prevailing party.”

Kalb v. Nack Holding, LLC, cited for the governing rule on attorney's fee timing.

Facts & Procedural History

Appellant 3003 Indian Creek RR, LLC appealed a trial court judgment entered in favor of Alfredo Arias and other appellees in Miami-Dade County.…

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Opinion of the Court

PER CURIAM.

Affirmed. See Kalb v. Nack Holding, LLC, 79 So. 3d 175, 176 (Fla. 3d

DCA 2012) (“[A] motion for attorney’s fees must be filed within thirty days of entry of final judgment to permit a trial court to award such fees. The only recognized exception to this requirement is when the trial court has already, in the judgment, determined entitlement to attorney’s fees as part of the relief granted to the prevailing party.”) (emphasis in original); Amerus

Life Ins. Co. v. Lait, 2 So. 3d 203, 207 (Fla. 2009) (“Once the trial court determines that the prevailing party is entitled to attorneys’ fees and costs,

the losing party is aware that it is required to pay the fees and costs. At that point, the concerns of prejudice and unfair surprise to the losing party are eliminated, thus eliminating the need to apply the thirty-day time requirement under [Florida Rule of Civil Procedure] 1.525.”); Ramle Int’l Corp. v. Greens

Condo. Ass’n, Inc., 32 So. 3d 647, 648 (Fla. 3d DCA 2010) (holding “the prevailing party’s entitlement to attorneys’ fees had already been determined, and the trial court merely reserved jurisdiction to determine the amounts”); Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979) (“Without a record of the trial proceedings, the appellate court can not properly resolve the underlying factual issues so as to conclude that the trial court’s judgment is not supported by the evidence or by an alternative theory.”).


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