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Clearwater Bonding Agency v. Pinellas County

Citations: 805 So. 2d 901; 2001 Fla. App. LEXIS 14484; 2001 WL 1201354Docket: No. 2D00-303

Court: District Court of Appeal of Florida; October 12, 2001; Florida; State Appellate Court

Narrative Opinion Summary

In this case, a bonding agency representing an accredited surety company appealed a trial court's denial of its motion for reconsideration regarding costs associated with a bond forfeiture. The primary legal issue involved the trial court's amendment of an order to impose a $40 fee for setting aside a bond forfeiture, which the bonding agency argued was unauthorized and arbitrary. The trial court initially imposed a $3 fee but later amended it to $40 based on a processing fee schedule. The appellate court found the motion for reconsideration untimely under Florida Rule of Civil Procedure 1.530(b). However, it determined that the trial court lacked jurisdiction to amend the order since the amendment was made more than ten days after the original order, violating Rule 1.530(d). The appellate court vacated the amended order, referencing the precedent in Easy Bail Bonds v. Polk County, which restricted allowable costs to those incurred by the sheriff's office in returning defendants. The original $3 fee was not contested by the appellant and thus was not addressed by the court. Consequently, the amended order was vacated, and the appellate court's decision was unanimous.

Legal Issues Addressed

Allowable Costs in Bond Forfeiture Cases

Application: Costs in bond forfeiture cases are limited to those incurred by the sheriff’s office in returning defendants, as established in Easy Bail Bonds v. Polk County.

Reasoning: The appellate court vacated the amended order, referencing a prior decision (Easy Bail Bonds v. Polk County) that established the only allowable costs for bail bondsmen in bond forfeiture cases are those incurred by the sheriff's office in returning defendants.

Jurisdiction to Amend Final Orders

Application: The trial court lacked jurisdiction to amend the final order after the expiration of the ten-day period specified in Florida Rule of Civil Procedure 1.530(d).

Reasoning: Although the appellate court agreed with the trial court's assessment of timeliness, it found that the trial court lacked jurisdiction to amend the final order since the amendment occurred more than ten days after the original order was entered, violating Florida Rule of Civil Procedure 1.530(d).

Timeliness of Motion for Reconsideration

Application: The trial court correctly deemed the motion for reconsideration untimely according to Florida Rule of Civil Procedure 1.530(b).

Reasoning: The trial court denied the motion, deeming it untimely under Florida Rule of Civil Procedure 1.530(b).