In HCA Health Services of Florida v. Jo Ann Berlin, M.D., 4D2022-2652 (April 17, 2024), the Fourth District Court of Appeal held the trial court abused its discretion when it denied HCA attorneys’ fees because HCA had not set the hearing on the amount of fees to be awarded within 90 days after the fee entitlement order, as ordered by the trial court. The Fourth District reversed the denial of attorneys’ fees because the delay in scheduling the hearing to determine the amount of fees to be awarded pursuant to HCA’s timely filed motion did not deprive the trial court of jurisdiction to award fees. Rule 1.525 only requires that a motion for attorneys’ fees be filed within 30 days after filing of the judgment or notice that concludes the action as to that party.

In short: Even if there’s a delay in scheduling a hearing for attorney’s fees, as long as the motion was timely filed the court can still decide on the fees.