The rules here come from two Florida Supreme Court cases. The first, Rowe, set the basic formula: count the hours reasonably spent, set a reasonable hourly rate, multiply the two, and adjust where appropriate. The second, Quanstrom, added the test for when a multiplier is justified – chiefly, whether the market requires one to attract competent counsel, and whether the lawyer could have reduced the risk of not being paid. Evidence has to back all of it.
Florida court wipes out 2.5 fee multiplier against Universal Property
