Attorney’s Fee as an Element of Compensatory Damages

When attorney’s fees are being sought as an element of compensatory damages, there is NO requirement for an expert to opine as to the reasonableness of the attorney’s fees. Rodriguez v. Altomare, 261 So.3d 590, 592 (Fla. 4th DCA 2018). “If, however, a party is seeking to recover previously incurred attorney’s fees as an element of compensatory damages in a separate breach of contract action, that party is not required to provide an independent expert witness to corroborate the reasonableness of the fees.” Id. See also Sea World of Florida, Inc. v. Ace American Ins. Companies, Inc., 28 So.3d 158,...