Clautide Jean-Pierre, James Jean-Pierre, & Reynold Jean-Pierre v. Madeline Glaberman, 192 So. 3d 613 (Fla. 4th DCA 2016). · Go Syfert
Clautide Jean-Pierre, James Jean-Pierre, & Reynold Jean-Pierre v. Madeline Glaberman, 192 So. 3d 613 (Fla. 4th DCA 2016). Cases Citing This Book View Copy Cite
5 citation events (5 in the last 25 years) across 1 distinct court.
Cited for
At page 613 Reviewing trial court orders awarding attorney's fees4 citing casesreversing fee order under section 57.105(1) when the trial court "failed to make detailed findings in its order regarding the basis for the fees sanction1 citing court put it this way
  • Russell v. Mells, 426 So. 3d 913 (Fla. 2d DCA 2025).published
    Phase III Homeowners Ass'n, 326 So. 3d 1181 , 1185 (Fla. 2d DCA 2021) ("A fee award as a sanction under section 57.105(1) requires the circuit court to make detailed findings on the basis of its award." (citing Jean-Pierre v. Glaberman, 19…
  • Felix Soto v. Carrollwood Vill. Phase I I I, 326 So. 3d 1181 (Fla. 2d DCA 2021).published
    (reversing fee order under section 57.105(1) when the trial court "failed to make detailed findings in its order regarding the basis for the fees sanction)
  • Austin & Laurato, P.A. v. State Farm Florida Ins. Co., 229 So. 3d 911 (Fla. 5th DCA 2017).published 2 cites
    Jean-Pierre v. Glaberman, 192 So. 3d 613, 613 (Fla. 4th DCA 2016) (quoting Lago v. Kame By Design, LLC, 120 So. 3d 73, 74 (Fla. 4th DCA 2013)).
  • Timothy Rose v. Bethany Rose, No. 6D2023-4209 (Fla. 6th DCA Mar. 27, 2026).published
    (Generally, the standard of review of a trial court’s order awarding section 57.105(1) attorney’s fees is abuse of discretion. However, to the extent a trial court’s order on fees is based on an issue of law, this court…)
Retrieving the full opinion text from the archive…
Clautide JEAN-PIERRE, James Jean-Pierre, and Reynold Jean-Pierre, Appellants,
v.
Madeline GLABERMAN, Appellee
4D15-2582.
District Court of Appeal of Florida, Fourth District.
May 25, 2016.
Published opinion
192 So. 3d 613
2016 WL 3010462
2016 Fla. App. LEXIS 7974
James Jean-Francois of James Jean-Francois, P.A., Hollywood, for appellants., No brief filed for appellee.
Warner, Conner.
Cited by 4 opinions  |  Published
PER CURIAM.

. The homeowners appeal three trial court orders (1) entering a final judgment of foreclosure in favor of appellee, (2) entering a -writ of bodily attachment against the homeowners, and (3) granting the appel-lee’s motion for attorney’s fees pursuant to section 57.105. We affirm the first, two orders without discussion, and reverse the third order because the trial court failed to make written findings regarding the reasons for granting the motion.

The underlying dispute in this case involved a mortgage foreclosure. During the pendency of the case, the appellee filed a motion for attorney’s fees, pursuant to section 57.105, Florida Statutes (2015), which was granted by the trial court, holding the homeowners and their legal counsel “jointly and severally liable for sanctions in the form of attorney’s fees.”

“Generally, the standard of review of a trial court’s order awarding section 57.105(1) attorney’s fees is abúse of discretion. However, to the extent a trial court’s order on fees is based on an issue of law, this court applies de novo review.” Lago v. Kame By Design, LLC, 120 So.3d 73, 74 (Fla. 4th DCA 2013) (citations omitted).

We agree with the homeowners that the trial court erred when it failed to make detailed findings in its order regarding the basis for the fees sanction. In Blue Infiniti, LLC v. Wilson, 170 So.3d 136 (Fla. 4th DCA 2015), we explained:

[*614] Additionally, the 'only finding that the trial court made in its order Was its “finding the Civil RICO claim was frivolous.” This falls short of the requirement that the trial court make detailed and specific findings of bad faith. “[I]f the trial court concludes that an award of fees under section 57,105 is an appropriate sanction, ‘it should recite in its order the facts upon which it bases that conclusion.’ ” Logo, 120 So.3d at 75 (quoting Regions Bank v. Gad, 102 So.3d 666, 667 (Fla. 1st DCA 2012)); see also Avis Rent A Car Sys., Inc. v. Newman, 641 So.2d 915 (Fla. 3d DCA 1994). It'was therefore error for the trial court to impose sanctions upon Blue Infiniti and its attorney prior to affording a full opportunity to be heard and without making detailed findings in its order;

Id. at 140-41, Since there are no findings of fact in the order on the motion for sanctions in this case, the order does not fully comply with the requirements of the law. Therefore, we remand the case for the trial court to make the appropriate findings. See id. (reversing and remánd-ing for the trial court to allow for a full hearing); cf. Bank of New York Mellon v. Kossis, 165 So.3d 793, 796 (Fla. 4th DCA 2015) (remanding, in a case that required written findings of fact, for the trial court to make such findings).

Affirmed in part, reversed in part, and remanded. ■ ■

WARNER, MAY and CONNER, JJ., ' concur.