MACCHITELLI
v.
GAFFNEY, BAUMANN, ET AL

Fla. 2d DCA | 2026-09-18
No. 2025-1735
Black, J., Kelly, J., Guard, J., Barton, II, Senior Judge
2026 FL 12233 Florida District Court of Appeal, Second District (2026)

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Holding

A trial court's finding of entitlement to attorney's fees and costs is not reviewable on certiorari when the court has not set the amount of fees and costs.


Headnotes

[1] A trial court's finding that a party is entitled to attorney's fees and costs is not reviewable on certiorari when the trial court has not set the amount of the fees and…

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Facts & Procedural History

Attorney James Macchitelli sought certiorari review of a postjudgment sanctions order rendered by the trial court on June 25, 2025. Macchitelli challe…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF FLORIDA

SECOND DISTRICT

JAMES J. MACCHITELLI, Petitioner,

V.

TERESA MARIE GAFFNEY; PHILLIP A. BAUMAN, administrator ad litem of the Estate of John J. Gaffney, deceased; and MICHAEL RYAN KANGAS, successor administrator ad litem of the Estate of John J. Gaffney, deceased,

Respondents.

No. 2D2025-1735

September 18, 2026

Petition for Writ of Certiorari to the Circuit Court for Hillsborough County; James M. Barton, II, Senior Judge.

James J. Macchitelli, pro se.

Michael Ryan Kangas, pro se.

No appearance by remaining Respondents.

BLACK, Judge.

Attorney James Macchitelli seeks certiorari review of the postjudgment sanctions order rendered June 25, 2025. We treat this certiorari proceeding as a direct appeal. See Fla. R. App. P. 9.040(c); cf.

Graham v. Graham, 898 So. 2d 210, 211 (Fla. 2d DCA 2005); Delgado v. Hearn, 805 So. 2d 1017, 1017 (Fla. 2d DCA 2001). To the extent that Mr. Macchitelli challenges the trial court's finding of entitlement to attorney's fees and costs, we dismiss for lack of jurisdiction because the trial court did not set the amount. See SP Healthcare Holdings, LLC v. Surgery Ctr. Holdings, LLC, 208 So. 3d 775, 781-82 (Fla. 2d DCA 2016). The sanctions order is otherwise affirmed.

Affirmed in part; dismissed in part.

KELLY and GUARD, JJ., Concur.

Opinion subject to revision prior to official publication.

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