Kemp v. Kemp

In this post-dissolution proceeding, we affirm the trial court’s judgment of contempt in all respects, save one. Under prevailing law, the trial court must make findings to substantiate an award of attorney’s fees to allow for meaningful appellate review. See DeLillo v. DeLillo, 848 So.2d 454, 455 (Fla. 4th DCA 2003). When someone other than an attorney’s own client is required to pay their fees, the trial court must award a reasonable fee, determined from testimony (absent any stipulations) as to the prevailing rates for attorneys in comparable circumstances and the amount of time reasonably…