CITIZENS PROPERTY INSURANCE CORPORATION v. WEBER (2026)

Citizens Property Insurance Corporation appeals a final judgment awarding attorney's fees and costs in favor of its insureds, appellees Rosanna and Randy Weber, challenging the award of a contingency fee multiplier to the Webers’ trial co-counsel, Alvarez Feltman Da Silva & Costa, PLLC, and the award of post-judgment interest calculated at a fixed rate.¹ Because the trial court's application of a contingency fee multiplier is supported by competent, substantial evidence, we affirm the final judgment awarding attorney's fees and costs. However, the Webers commendably acknowledge that the final judgment erroneously provides that post-judgment interest is to be calculated at a constant rate until the judgment is satisfied. See § 55.03(3), Fla. Stat. (2025) (“The interest rate is established at the time a judgment is obtained and such interest rate shall be adjusted annually on January 1 of each year in accordance with the interest rate in effect on that date as set by the Chief Financial Officer until the judgment is paid ․”); Townsend v. R.J. Reynolds Tobacco Co., 192 So. 3d 1223, 1224–25 (Fla. 2016). Accordingly, we remand with directions to amend the final judgment to provide for a variable rate of interest in accordance with section 55.03(3).

Affirmed in part, reversed in part, and remanded with directions.

FOOTNOTES

1.   “ ‘Both the fee award and application of a multiplier are reviewed for an abuse of discretion,’ and therefore must be supported by competent, substantial evidence.” Little v. Bath & Kitchen Boutique, LLC, 435 So. 3d 1142, 1144 n.1 (Fla. 3d DCA 2026) (citation omitted) (quoting Certain Underwriters at Lloyd's London v. Candelaria, 339 So. 3d 463, 467 (Fla. 3d DCA 2022)); see also 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.”).

PER CURIAM.