Cox v. Great American Insurance Co.

This is the fifth appeal from an order awarding attorney’s fees as a sanction in civil litigation. In the fourth appeal, Cox v. Great American Insurance Company, 88 So.3d 1048 (Fla. 4th DCA 2012), this Court reversed the sanction order for failure to comply with procedural requirements. Id. at 1049. The order had failed to include specific factual findings detailing the sanctionable conduct of appellant as well as the attorney’s fees appellee incurred as a result of that conduct. Id. We also reversed the award of fees because it impermissibly included fees for time spent litigating fees. Id.…