ADRIANO CUESTA RODRIGUEZ
v.
CANEL JAMIEL AUGUSTE, ET AL.
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Costs for non-testifying experts are not taxable, and trial courts have broad discretion in awarding costs.
[1] Costs for expert witnesses who do not testify at trial are not taxable as costs under Florida law.
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“it is clear that taxable costs for experts do not include costs for those experts who do not testify. Therefore, costs for non-testifying experts are nontaxable.”
Court's statement of the rule regarding expert witness costs
Adriano Cuesta Rodriguez appealed a cost award decision from Miami-Dade County Court.…
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Third District Court of Appeal State of Florida
Opinion filed April 23, 2025. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D24-2224 Lower Tribunal No. 23-20898-SP-26 ________________
Adriano Cuesta Rodriguez, Appellant,
vs.
Canel Jamiel Auguste, et al., Appellees.
An Appeal from the County Court for Miami-Dade County, Lawrence
D. King, Judge.
Adriano Cuesta Rodriguez, in proper person.
No appearance, for appellees.
Before LOGUE, C.J., and LINDSEY and BOKOR, JJ.
PER CURIAM.
2
Affirmed. See Field Club, Inc. v. Alario, 180 So. 3d 1138, 1142 (Fla. 2d DCA 2015) (emphasizing that “the trial court has broad discretion in awarding costs”); R.J. Reynolds Tobacco Co. v. Lewis, 275 So. 3d 747, 750 (Fla. 5th DCA 2019) (“[I]t is clear that taxable costs for experts do not include costs for those experts who do not testify. Therefore, costs for nontestifying experts are nontaxable.”).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- The Field Club, Inc. v. Alario, 180 So. 3d 1138 (Fla. 2d DCA 2015)
- R.J. Reynolds Tobacco Co. v. Lewis, 275 So. 3d 747 (Fla. 5th DCA 2019)