DOMINICK CALDERONE
v.
CURTIS STOKES AND ASSOCIATES, INC

Fla. 4th DCA | 2021-06-16
No. 21-0495
Judge Christopher R. Cooper
Florida District Court of Appeal, Fourth District (2021)

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Holding

A party cannot recover attorney's fees if the claim was not pled and there is no statutory or contractual basis for the fees.


Headnotes

[1] A claim for attorney's fees must be pleaded; failure to request such fees constitutes a waiver of the claim regardless of whether a statutory or contractual basis exists.

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Key Quotes

“A claim for attorney's fees, whether based on statute or contract, must be pled. Failure to do so constitutes a waiver of the claim.”

Court's statement of the controlling legal principle from Stockman v. Downs.

Facts & Procedural History

A brokerage firm brought an action to recover a commission on a boat sale. The trial court awarded the firm $3,490 in commission, $300 in costs, and $…

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Opinion of the Court

PER CURIAM.

This case involves a dispute over a brokerage commission on a boat sale. The seller appeals a judgment awarding the brokerage firm a $3,490 commission, $300 in costs, and $1,510 in attorney’s fees. We affirm without comment the judgment as it relates to the commission and costs. However, we reverse the attorney’s fees award because the brokerage firm did not request attorney’s fees, and there was no statutory or contractual basis for fees. See Stockman v. Downs, 573 So. 2d 835, 837-38 (Fla. 1991) (“[A] claim for attorney’s fees, whether based on statute or contract, must be pled. Failure to do so constitutes a waiver of the claim.”); Moakley v. Smallwood, 826 So. 2d 221, 224 (Fla. 2002).

Affirmed in part, reversed in part, and remanded. LEVINE, C.J., MAY and FORST, JJ., concur.

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