Harris v. McKinney

DAVIS, Judge,

Specially concurring.

I fully concur with the majority opinion; however, I write to express my concerns over the disparate treatment provided to attorney’s fees orders under the case law as previously expressed by this court. In many of the instances in which the trial court is required to make specified findings of fact, the failure to include the findings in the written order is not subject to review when the appellate record lacks a transcript of the proceedings below or an appropriate substitute. See, e.g., Esaw v. Esaw, 965 So.2d 1261 (Fla. 2d DCA 2007) (affirming equitable…