THOMAS P. SCHMITT AND FLORIDA PERSONAL INJURY LAW TEAM, LLC
v.
FLORIDA INJURY LAW FIRM, PA

Fla. 6th DCA | 2026-06-05
No. 2023-2483
Jordan, J., Nardella, J., White, J., Brownlee, J.
2026 FL 6861 Florida District Court of Appeal, Sixth District (2026)

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Holding

An appellate court lacks jurisdiction to review judicial rulings occurring after the filing of a notice of appeal.


Headnotes

[1] An appellate court lacks jurisdiction to review judicial rulings or orders rendered after the filing of a notice of appeal.

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Key Quotes

“Pursuant to this rule, Florida appellate courts deny review of judicial acts occurring after the filing of a notice of appeal.”

Court citing Santos v. HSBC Bank USA, Nat'l Ass'n as Tr. for Holders of the GSAA Home Equity Tr. 2005-07, 258 So. 3d 535, 537 (Fla. 3d DCA 2018)

Facts & Procedural History

Appellants Thomas P. Schmitt and Florida Personal Injury Law Team, LLC appealed from a circuit court decision in Orange County. After filing their not…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 6D2023-2483 Lower Tribunal No. 2018-CA-002535-O

THOMAS P. SCHMITT and FLORIDA PERSONAL INJURY LAW TEAM, LLC, Appellants,

V.

FLORIDA INJURY LAW FIRM, P.A., Appellee.

Appeal from the Circuit Court for Orange County. John E. Jordan, Judge.

June 5, 2026

PER CURIAM.

As to Appellants' challenge to the order denying their motion for attorney's fees rendered after Appellants filed their notice of appeal, we dismiss this appeal. See Fla. R. App. P. 9.110(h) (“[T]he court may review any ruling or matter occurring before filing of the notice."); see also, e.g., Santos v. HSBC Bank USA, Nat'l Ass'n as Tr. for Holders of the GSAA Home Equity Tr. 2005-07, 258 So. 3d 535, 537 (Fla. 3d DCA 2018) ("Pursuant to this rule, Florida appellate courts deny review of judicial acts occurring after the filing of a notice of appeal."). Otherwise, we affirm in all respects without further discussion.

AFFIRMED in part; DISMISSED in part.

NARDELLA, WHITE and BROWNLEE, JJ., concur.

Chad A. Barr and Dalton L. Gray, of Chad Barr Law, Altamonte Springs, for Appellants.

Roy D. Wasson, of Wasson & Associates, Chartered, Miami, for Appellee.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING

AND DISPOSITION THEREOF IF TIMELY FILED

2


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