In a recent case, Hurst v. Bell, 51 Fla. L. Weekly D1542a (Fla. 2d DCA 2026), a plaintiff recovered attorney’s fees against a defendant in an automobile accident case. The defendant was defended by its automobile liability insurer. The plaintiff recovered attorney’s fees based on the proposal for settlement statute. The plaintiff served a proposal for settlement, the defendant (insurer) did not accept the proposal, and the plaintiff recovered a judgment that triggered rights to fees under the proposal for settlement statute. The plaintiff tried to join the defendant’s automobile liability insurer to the attorney’s fees judgment under Florida Statute s. 627.4136(4). The problem was that the policy that expressly stated, “This does not include attorney’s fees awarded or assessed against an insured person.” In other word, the policy did NOT cover an award of attorney’ fees entered against its insured. Thus, while the insured was liable for the fees, and perhaps this raises a separate issue with its insurer, the insurer was not liable for such fees under the policy. “Because the policy does not cover the attorney’s fee portion of the judgment, section 627.4136(4) supplies no basis to join [insurer] to that judgment. The circuit court therefore correctly granted [insurer’s] exceptions to the magistrate’s recommendation, which had the effect of denying the [plaintiff’s] amended motion to add [insurer] to that judgment.” See Hurst, supra.