Divorce Law in Florida

ATTORNEY FEES - Contempt and ability to Pay.

The law is well established that the trial court must set forth specific
findings concerning the hourly rate, the number of hours reasonably
expended and the appropriateness of reduction or enhancement factors.
See Fla. Patient’s Comp. Fund v. Rowe, 472 So. 2d 1145, 1151 (Fla.
1985); see also Macarty v. Macarty, 29 So. 3d 434, 435 (Fla. 2d DCA
2010) (‘“[A]n award of attorney’s fees without adequate findings justifying
the amount of the award is reversible even where the appellant has
provided an inadequate record of the trial court proceedings.’” (quoting
Esaw v. Esaw, 965 So. 2d 1261, 1265 (Fla. 2d DCA 2007))). “The
presence of competent substantial evidence to support the award does
not obviate the need for such specific findings.” Hoffay v. Hoffay, 555
So. 2d 1309, 1310 (Fla. 1st DCA 1990).