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State Department of Transportation v. Fortune Federal Savings & Loan Ass'n

Citations: 489 So. 2d 1216; 11 Fla. L. Weekly 1349; 1986 Fla. App. LEXIS 8303Docket: No. 86-1059

Court: District Court of Appeal of Florida; June 11, 1986; Florida; State Appellate Court

Narrative Opinion Summary

The Department of Transportation filed for a writ of certiorari to overturn an order that granted Fortune Federal Savings and Loan Association $30,000 in partial attorney’s fees during an ongoing condemnation proceeding. The Department argued, referencing the case of Department of Transportation v. Decker, that the court lacked the authority to award such fees before the proceedings were concluded. The court agreed, noting that while there may be circumstances justifying partial attorney’s fee awards, Florida law (sections 73.091 and 73.092, Florida Statutes) does not allow for interim attorney’s fee awards in condemnation cases. Consequently, the court quashed the order for partial fees and stated that attorney’s fees could be awarded at the case's conclusion under section 73.092. Judges Grimes and Schoonover concurred with this decision.

Legal Issues Addressed

Authority to Award Attorney's Fees in Condemnation Proceedings

Application: The court determined that it lacked the authority to award partial attorney's fees before the conclusion of condemnation proceedings as per existing Florida statutes.

Reasoning: The Department argued, referencing the case of Department of Transportation v. Decker, that the court lacked the authority to award such fees before the proceedings were concluded.

Finality of Attorney's Fee Awards in Condemnation Cases

Application: The court concluded that attorney's fees may be awarded at the end of the case, aligning with section 73.092 of the Florida Statutes.

Reasoning: Consequently, the court quashed the order for partial fees and stated that attorney’s fees could be awarded at the case's conclusion under section 73.092.

Interim Attorney's Fee Awards under Florida Law

Application: The court found that Florida law does not permit interim attorney's fees in condemnation cases, emphasizing that awards should only be granted at the conclusion of the proceedings.

Reasoning: The court agreed, noting that while there may be circumstances justifying partial attorney’s fee awards, Florida law (sections 73.091 and 73.092, Florida Statutes) does not allow for interim attorney’s fee awards in condemnation cases.