In Certain Underwriters at Lloyd’s London v. Roniel Candelaria & Amelia Padura, 3D20-871, 2022 WL 1559917 (Fla. 3d DCA May 18, 2022), the Third District reversed a fee award in a first party property case.  At an evidentiary hearing, Plaintiff’s fee expert “cut 7.5 percent” of the total hours claimed, but did not elaborate as to the basis for the reduction. Plaintiffs’ expert also opined that a 2.45 multiplier was appropriate based on the law firm being “one of the best” and that plaintiffs would have had a hard time getting a good lawyer to take the case without a multiplier.  In contrast, defendant’s expert undertook a detailed, itemized evaluation of each of plaintiff’s time entries and concluded that the reasonable time was significantly less than that presented. Defendant’s expert also disagreed that a multiplier was appropriate because there was no evidence that other counsel in the community would not have taken the case. In awarding fees, the trial judge doubled the reduction suggested by plaintiff’s expert and applied a 1.8 multiplier.  On appeal, the Third District rejected the trial court’s lodestar determination and held that “the trial court’s adoption of the insureds’ expert’s methodology of an arbitrary, ‘across-the-board’ reduction” was improper and not supported by competent substantial evidence. The Third District also rejected the trial court’s application of a contingency risk multiplier because it failed to consider each of the factors in Standard Guaranty Insurance Co. v. Quanstrom, 555 So. 2d 828, 834 (Fla. 1990), notably, the court failed to consider whether the attorney was able to mitigate the risk of nonpayment in any way. Read more here.