WILLIAMS
v.
WILLIAMS
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In a dissolution proceeding, an award of temporary attorneys' fees must be accompanied by factual findings regarding the reasonableness of both the hourly rates and time expended.
[1] In a dissolution of marriage proceeding, an award of temporary attorneys' fees must be supported by factual findings regarding both the reasonableness of the hourly rates…
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“the trial court must 'not only determine that one spouse has a need for suit money and the other has the ability to pay, but also that the temporary attorney's fees and costs awarded are reasonable.'”
Statement of the legal standard for awarding temporary attorneys' fees in dissolution proceedings, quoting Kasm v. Kasm.
In a dissolution of marriage case, the trial court awarded the former wife temporary attorneys' fees in the amount of $75,000. The former husband appe…
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DISTRICT COURT OF APPEAL OF FLORIDA
SECOND DISTRICT
RONALD BRIAN WILLIAMS, Appellant,
V.
SAMANTHA SMITH WILLIAMS, Appellee.
No. 2D2025-1777
August 14, 2026
Appeal pursuant to Fla. R. App. P. 9.130 from the Circuit Court for Pinellas County; Brian Gnage, Judge.
Michael Gonzalez of Gonzalez Law Group, Tampa, for Appellant.
William B. Bennett of William B. Bennett, P.A., St. Petersburg, for Appellee.
SMITH, Judge.
The Former Husband, Ronald Brian Williams, seeks review of a nonfinal order awarding the Former Wife, Samantha Smith Williams, temporary attorneys' fees in the amount of $75,000. We affirm, without discussion, the portion of the order concluding that the Former Wife is entitled to temporary fees. However, because the trial court failed to make findings as to the reasonableness of both the hourly rate charged and the hours claimed, we reverse the portion of the order awarding $75,000 in temporary fees and remand to the trial court for a determination of the reasonable amount of fees to be awarded. 1
When considering a request for attorneys' fees in a dissolution proceeding "[t]he trial court must 'not only determine that one spouse has a need for suit money and the other has the ability to pay, but also that the temporary attorney's fees and costs awarded are reasonable.' Kasm v. Kasm, 933 So. 2d 48, 50 (Fla. 2d DCA 2006) (quoting Safford v. Safford, 656 So. 2d 485, 486 (Fla. 2d DCA 1994)). This court has "consistently required that an award of temporary attorneys' fees be accompanied by factual findings regarding reasonableness of the hourly rates and time expended." Chhouri v. Chhouri, 2 So. 3d 987, 988 (Fla. 2d DCA 2008) (first citing Ghay v. Ghay, 954 So. 2d 1186 (Fla. 2d DCA 2007); and then citing Kasm, 933 So. 2d at 48). Accordingly, we reverse the portion of the order awarding the $75,000 in temporary attorneys' fees and remand for the trial court to make the appropriate findings in determining the reasonable amount of attorneys' fees to be awarded. See Chhouri, 2 So. 3d at 988; Kasm, 933 So. 2d at 50; Safford, 656 So. 2d at 486.
Affirmed in part, reversed in part, and remanded.
NORTHCUTT and GUARD, JJ., Concur.
Opinion subject to revision prior to official publication.
1 To the extent the Former Wife argues the order should be affirmed as a sanction, the order expressly states that the trial court reserved ruling on the Former Wife's motion for contempt.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Sunil Ghay v. Poonam Ghay, 954 So. 2d 1186 (Fla. 2d DCA 2007)
- Safford v. Safford, 656 So. 2d 485 (Fla. 2d DCA 1994)
- Kasm v. Kasm, 933 So. 2d 48 (Fla. 2d DCA 2006)
- Chhouri v. Adoline Chhouri, 2 So. 3d 987 (Fla. 2d DCA 2008)