Legal Topics

SECTION 57.105(1) AUTHORIZES ATTORNEY’S FEES BUT NOT COSTS

Jul 21st, 2026 in by admin

Rose v. Rose, 51 Fla. L. Weekly D639 (Fla. 6th DCA Mar. 27, 2026):

The trial court imposed sanctions against the appellant under section 57.105(1) in the form of attorney’s fees and costs. 

While the court affirmed the attorney’s fee award, it reversed the $75 in costs because the statutory text authorizes “a reasonable attorney’s fee” (including prejudgment interest) and says nothing about costs.  The court refused to add a costs component the Legislature did not include, affirming in part and reversing in part.