Arbitration & Mediation

First District Gives Quick Lesson to Requirements of an Order Granting 57.105 Sanctions

By Christopher B. Hopkins, Esq.

If you are fortunate enough to win a Motion for Sanctions under Florida Statutes 57.105, the one paragraph opinion in Diane Brown v. Pan Handle Citizens Coalition et al. (Per Curiam) may be valuable guidance for proposing an order.

The court held that an order granting 57.105 shall specify the number of attorney hours reasonably expended on the challenged claim. Moreover, there needs to be competent, substantial evidence in the record to support the fee award.

Full post as published by Florida Arbitration Law on September 17, 2009 (boomark / email).