Florida Statutes
Fla. Stat. § 772.104 (2025)
Civil cause of action.
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772.104 Civil cause of action.—
(1) Any person who proves by clear and convincing evidence that he or she has been injured by reason of any violation of the provisions of s. 772.103 shall have a cause of action for threefold the actual damages sustained and, in any such action, is entitled to minimum damages in the amount of $200, and reasonable attorney’s fees and court costs in the trial and appellate courts.
(2) As an alternative to recovery under subsection (1), any person who proves by clear and convincing evidence that he or she has been injured by reason of any violation of the provisions of s. 772.103 due to sex trafficking or human trafficking shall have a cause of action for threefold the amount gained from the sex trafficking or human trafficking and in any such action is entitled to minimum damages in the amount of $200 and reasonable attorney’s fees and court costs in the trial and appellate courts.
(3) In no event shall punitive damages be awarded under this section. The defendant shall be entitled to recover reasonable attorney’s fees and court costs in the trial and appellate courts upon a finding that the claimant raised a claim which was without substantial fact or legal support. In awarding attorney’s fees and costs under this section, the court shall not consider the ability of the opposing party to pay such fees and costs. Nothing under this section shall be interpreted as limiting any right to recover attorney’s fees or costs provided under other provisions of law.
Notes of Decisions
Cited in 114
cases (51 in the last 5 years), 1989–2026 · leading case: Rollins, Inc. v. Butland, 951 So. 2d 860 (Fla. 2d DCA 2006).
Rollins, Inc. v. Butland, 951 So. 2d 860 (Fla. 2d DCA 2006). “(misleading advertising); § 772.104, Fla. Stat. (Florida RICO). In addition, the Contract contains a provision for the award of attorney's fees in favor of Orkin.”
Allstate Ins. v. Palterovich, 653 F. Supp. 2d 1306 (S.D. Fla. 2009). “(Count VII); common law fraud (Count VIII); as well as the Florida Civil Remedies for Criminal Practices Act, Fla. Stat. §§ 772.104 and 772.11 (Counts IX-X); and, Plaintiffs sought injunctive relief (Count XI) and declaratory judgments (Counts XII-XIV) in addition to monetary…”
Bambu v. EI Dupont De Nemours & Co., Inc., 881 So. 2d 565 (Fla. 3d DCA 2004). “" § 772.104, Fla. Stat. (2003). Thus, to recover, the nurseries had to prove that they were injured "by reason of" DuPont's alleged criminal activities.”
Burgese v. Starwood Hotels & Resorts Worldwide, Inc., 101 F. Supp. 3d 414 (D.N.J. 2015). “Fla. Stat. § 772.104 (1) (emphasis added).”
Foreman v. EF Hutton & Co., Inc., 568 So. 2d 531 (Fla. 3d DCA 1990). “This is an appeal of an attorney's fee award to a defendant pursuant to section 772.104, Florida Statutes (1989).”
RLS BUS. VENTURES v. Second Chance Wholesale, Inc., 784 So. 2d 1194 (Fla. 2d DCA 2001). “§ 1964 (c); § 772.104, Fla. Stat., we believe federal cases interpreting the federal civil damages remedy are also persuasive in interpreting section 772.”
Ziccardi v. Strother, 570 So. 2d 1319 (Fla. 2d DCA 1990). “The basis of the complaint, filed in 1987 under section 772.104 Florida Statutes, was alleged criminal acts perpetrated against her by the appellees in 1979.”
Terminix Int'l Co. LP v. Palmer Ranch Ltd. P'ship, 432 F.3d 1327 (11th Cir. 2005). “, Florida RICO), Fla. Stat. § 772.104 ; criminal false advertising, Fla.”
Florida Evergreen Foliage v. E.I. DuPont De Nemours & Co., 336 F. Supp. 2d 1239 (S.D. Fla. 2004). “Plaintiff-Growers argue that they are alleging “negative fraud” such as concealment and destruction of evidence, which do not require a showing of reasonable reliance.”
Spadaro v. City of Miramar, 855 F. Supp. 2d 1317 (S.D. Fla. 2012). “City Response at 27 (citing Fla. Stat. § 772.104 (1)). However, the City Defendants only argue that Caravella's claims brought pursuant to 18 U.”
Remova Pool Fence Co. v. Roth, 647 So. 2d 1022 (Fla. 4th DCA 1994). “Section 772.104, Florida Statutes (1993), provides that the defendant in a civil action brought under that statute "shall be entitled to recover reasonable attorney's fees and *1025 costs in the trial and appellate courts upon a finding that the claimant raised a claim that was…”
STUART L. STEIN, PA v. Miller Indus., Inc., 564 So. 2d 539 (Fla. 4th DCA 1990). “035 conferring the ability of "any person" to pursue a civil theft claim to section 772.104 and elevated the standard of proof to the "clear and convincing" level.”
Absolute Activist Value Master Fund Ltd. v. Devine, 233 F. Supp. 3d 1297 (M.D. Fla. 2017). “…damages in the amount of 0, and reasonable attorney’s fees and court costs in the trial and appellate courts. Fla. Stat. § 772.104 (1).”
Small Bus. Admin. v. Echevarria, 864 F. Supp. 1254 (S.D. Fla. 1994). “App.1994). If the civil theft claim is successful, the Plaintiff is entitled to treble damages, as long as there is no contractual relationship between the parties.”
Cat Charter, LLC v. Schurtenberger, 646 F.3d 836 (11th Cir. 2011). “On the claim by Claimants for civil theft which the Arbitrators have denied, the Arbitrators find that Claimants raised a claim that had substantial fact and legal support pursuant to Fla. Stat. § 772.104 (3). More specifically, we find that the issues relating to missing resin…”
Haddad v. Cura, 674 So. 2d 168 (Fla. 3d DCA 1996). “Haddad moved post-trial, among other things, to treble these damages under section 772.104, Florida Statutes (1987).”
Med. Marijuana, Inc. v. Horn, 604 U.S. 593 (2025). “§16–14–6(c) (2024); Fla. Stat. §772.104 (1) (2023). But Congress instead decided to limit civil RICO suits to plaintiffs who have been “injured in” their “business or property.”
Clark A. Huls v. Lusan C. Llabona, 437 F. App'x 830 (11th Cir. 2011). “Huls alleged violations of Fla. Stat. §§ 772.104 (providing a civil cause of action for violations of Florida’s Criminal Practices Act); 843.”
Hartford Ins. Co. v. Miller, 681 So. 2d 301 (Fla. 3d DCA 1996). “To sum up, we agree with the trial judge that there was no substantial factual or legal support for the claim and that this was exactly the type of RICO claim that the legislature intended to discourage by section 772.104, Florida Statutes (1995).”
Friedman v. Lauderdale Med. Equip. Serv., Inc., 591 So. 2d 328 (Fla. 4th DCA 1992). “In construing a similar attorney's fee provision in section 772.104, Florida Statutes (1989), the Third District in Foreman v.”
Gordon Jones & Laura Jones v. John H. Childers & Talent Servs., Inc., 18 F.3d 899 (11th Cir. 1994). “2d 532 (1992) (holding that the phrase "by reason of” in federal RICO statute [employing similar language to Fla.Stat. § 772.104] requires that a plaintiff show that the acts in question proximately caused his damages); and Pelletier v.”
Lockheed Martin Corp. v. Boeing Co., 314 F. Supp. 2d 1198 (M.D. Fla. 2004). “Criminal activity includes several predicate crimes named in section 772.104(1), Florida Statutes, and a “pattern of criminal activity” under the Florida RICO Act consists of engaging in at least two incidents of criminal activity that have the same or similar intents, results,…”
Bortell v. White Mountains Ins. Grp., Ltd., 2 So. 3d 1041 (Fla. 4th DCA 2009). “Section 772.104(1) provides, “Any person who proves by clear and convincing evidence that he or she has been injured by reason of any violation of the provisions of s.”
Anthony Distributors, Inc. v. Miller Brewing Co., 941 F. Supp. 1567 (M.D. Fla. 1996). “§ 772.104 (1995). That statute reads, in pertinent part: Any person who proves by clear and convincing evidence that he has been injured by reason of any violation of the provisions of [Section] 772.”
Coffey v. Evans Props., Inc., 585 So. 2d 960 (Fla. 4th DCA 1991). “Meanwhile Evans moved for costs and attorney's fees to be assessed against Coffey for the dismissed claims, without mentioning section 772.104 or any other statutory or contractual basis for fees.”
Ciaramello v. D'Ambra, 613 So. 2d 1324 (Fla. 2d DCA 1991). “3d DCA 1990), holding similar language found in section 772.104, Florida Statutes, to be interpreted as authorizing attorney's fees where a claim lacks either legal or factual substance.”
Fixel v. Marsowicz (In Re Marsowicz), 120 B.R. 602 (Bankr. S.D. Florida 1990). “4th DCA 1990); Fla.Stat. Ann. § 772.104 (WEST 1990). This is the same standard of proof which this Court must apply in determining whether the debt owed by the debtors to the creditors is dischargeable.”
Bronson v. Bronson, 685 So. 2d 994 (Fla. 5th DCA 1997). “3rd DCA 1990) and section 772.104, Florida Statutes (1995), the trial court erred in failing to award him attorney's fees for successfully defending against the civil theft count.”
Garrison v. State, 553 So. 2d 1377 (Fla. 2d DCA 1989). “2d Conversion §§ 117-121 (1985); § 772.104, Fla. Stat. (1987). Under the evidence presented to the trial court, that court could reasonably conclude that Mr.”
Tambourine Comercio Internacional SA v. Solowsky, 312 F. App'x 263 (11th Cir. 2009). “Fla. Stat. § 772.104 (2007). “Clear and convincing evidence is an standard between the preponderance of the evidence standard and the criminal beyond a reasonable doubt Echevarria, 864 F.”
Mitchell v. Consol. Freightways Corp. of Del., 747 F. Supp. 1446 (M.D. Fla. 1990). “, Fla.Stat. §§ 772.104, 812.035, 895.05, these exclusions involve civil redress for actions in which punitive damages could be expected to be otherwise available.”
Ace Pro Sound & Recording, LLC v. Albertson, 512 F. Supp. 2d 1259 (S.D. Fla. 2007). “• Count 2 against Defendant Albertson for a pattern of extortion activity in violation of the Florida Racketeer Influenced and Corrupt Organizations Act (Florida’s RICO Act), Fla. Stat. § 772.104 . 3 *1262 • Count 3 against Defendant Albertson for unconscionable acts and unfair…”
McKenzie v. Betts, 55 So. 3d 615 (Fla. 4th DCA 2011). “2105(3) (“The trial judge may award *618 the prevailing party the sum of reasonable costs incurred in the action plus a reasonable legal fee for die hours actually spent on the case.”
Rollins, Inc. v. Butland, 932 So. 2d 1172 (Fla. 2d DCA 2006). “(misleading advertising); § 772.104, Fla. Stat. (Florida RICO). In addition, the Contract contains a provision for the award of attorney's fees in favor of Orkin.”
COMPTECH INTERN. v. Milam Com. Park, 711 So. 2d 1255 (Fla. 3d DCA 1998). “By legislative declaration, the statutory causes of action for civil theft (and, for that matter, section 772.104, Florida Statutes, the cause of action for racketeering) are in addition to any other remediesand therefore are in addition to any remedy which might exist for…”
Boczar v. Manatee Hospitals & Health Sys., Inc., 731 F. Supp. 1042 (M.D. Fla. 1990). “19 of Florida’s Antitrust Law, 8) violation of Florida Statute Section 772.104, 9) violation of Florida Statute Section 772.”
Palm Beach Atl. Coll., Inc., Cross-Appellant v. First United Fund, Ltd., Stanmar Corp., Mario Renda, Cross-Appellees, 928 F.2d 1538 (1st Cir. 1991). “See Fla.Stat. § 772.104 (Supp.1990). Section 772.”
Capital Factors, Inc. v. Gen. Plastics Corp. (In Re Gen. Plastics Corp.), 170 B.R. 725 (Bankr. S.D. Florida 1994). “1992) (reversing denial of fees under similar provision of § 772.104 where no evidence presented that defendant did anything that was not protected under First Amendment).”
Skubal v. Cooley, 650 So. 2d 169 (Fla. 4th DCA 1995). “3d DCA 1990) (discussing standard under identically worded attorney's fees provision of section 772.104). While section 57.105 requires a finding of a complete absence of a justiciable issue of either law or fact before a losing party would be obligated to pay the opposing…”
Fid. Warranty Servs., Inc. v. Firstate Ins. Holdings, Inc., 98 So. 3d 672 (Fla. 4th DCA 2012). “” §§ 772.104(8), 812.035(7), Fla. Stat. The trial court found that the directed verdict was sufficient to trigger JMA’s entitlement to fees under the statutes, but denied the motion for fees after JMA failed to isolate the attorney time spent on the civil theft counterclaim.”
Pincus v. Speedpay, Inc., 161 F. Supp. 3d 1150 (S.D. Fla. 2015). “204 (count six); Florida civil remedies for Criminal Procedures Act (“CRCPA”), Florida Statute § 772.104 (count seven) and Racketeer Influenced and Corrupt Organizations (“RICO”), 18 U.”
Smith v. Viragen, Inc., 902 So. 2d 187 (Fla. 3d DCA 2005).
Eagletech Commc'ns, Inc. v. Bryn Mawr Inv. Grp., Inc., 79 So. 3d 855 (Fla. 4th DCA 2012). “Section 772.104(1) provides civil remedies for violations of section 772.”
Ciaramello v. D'Ambra, 590 So. 2d 946 (Fla. 2d DCA 1991).
Moore Bus. Forms, Inc. v. Iberoamerican Elec., S.R.L., 698 So. 2d 611 (Fla. 4th DCA 1997).
Balas v. Ruzzo, 703 So. 2d 1076 (Fla. 5th DCA 1998).
Ivans v. McKid Ltd., 642 So. 2d 798 (Fla. 3d DCA 1994).
City of North Bay Vill. v. Cook, 617 So. 2d 753 (Fla. 1st DCA 1993).
In Re Rospatch Sec. Litig., 760 F. Supp. 1239 (W.D. Mich. 1991).
Manuel Soltero v. Swire Dev. Sales, Inc., 485 F. App'x 377 (11th Cir. 2012).
DJ Lincoln Enter., Inc. v. Google, LLC (S.D. Fla. 2022). “The Report and Recommendation cites well-reasoned caselaw standing for the proposition that achieving the dismissal with prejudice of a Florida RICO claim due to failure to state a claim does enable the defendant to collect attorneys’ fees under § 772.104(3). Plaintiff…”
Steve Ferguson v. the Repub. of Trinidad & Tobago (Fla. 3d DCA 2025). “§ 772.104(1), Fla. Stat. Florida Civil RICO’s substantive provisions provide it is unlawful for any person to use the proceeds “from a pattern of criminal activity.”
Steve Ferguson v. the Repub. of Trinidad & Tobago (Fla. 3d DCA 2025). “§ 772.104(1), Fla. Stat. Florida Civil RICO’s substantive provisions provide it is unlawful for any person to use the proceeds “from a pattern of criminal activity.”
Eaton v. The Bank of New York Mellon (N.D. Fla. 2021). “Fee Entitlement under § 772.104(3), Florida Statutes.1 As noted above, Florida’s Civil Remedies for Criminal Practices Act mandates fees to a prevailing defendant where a plaintiff raises a claim without substantial fact or legal support.”
Beck v. Olstein, 588 So. 2d 317 (Fla. 3d DCA 1991).
Bahrakis v. Zimmerman (M.D. Fla. 2020). “Section 772.104(3) provides that a defendant is entitled to recover reasonable attorneys’ fees “upon a finding that the claimant raised a claim which was without substantial fact or legal support.”
S. Y. v. Jay Varahimata Investments, LLC. (M.D. Fla. 2021).
S.Y. v. Uomini & Kudai, LLC (M.D. Fla. 2021).
Depoalo v. Deutsche Bank Nat'l Trust Co. (M.D. Fla. 2021).
2950 Summer Swan Land Trust v. Deutsche Bank Nat'l Trust Co. (M.D. Fla. 2021).
Kenny v. Deutsche Bank Nat'l Trust Co. (M.D. Fla. 2021).
Weber v. Deutsche Bank Nat'l Trust Co. (M.D. Fla. 2021).
S.Y. v. Holistic Health Healing, Inc. (M.D. Fla. 2021).
Mkt. Tampa Investments, LLC v. Deutsche Bank Nat'l Trust Co. (M.D. Fla. 2021).
S.Y. v. Sea Shell Mgmt., LLC (M.D. Fla. 2021).
Quest Sys. LLC v. Deutsche Bank Nat'l Trust Co. (M.D. Fla. 2021).
C.S. v. Holistic Health Healing, Inc. (M.D. Fla. 2021).
S.Y. v. Naples Hotel Co. (M.D. Fla. 2021).
S.Y. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
S.Y. v. Marriott Int'l, Inc. (M.D. Fla. 2021).
Royal Palm Vill. Residents, Inc. v. Slider (M.D. Fla. 2021).
Hollander (M.D. Fla. 2026).
In re Barrett Home Corp., 165 B.R. 50 (Bankr. M.D. Fla. 1994).
Atlantis Grp., Inc. v. Rospatch Corp., 760 F. Supp. 1239 (W.D. Mich. 1991).
Omnipol, a.S. v. Multinational Def. Servs., LCC (M.D. Fla. 2020).
C.S. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
S.Y. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
S.Y. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
S.Y. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
S.Y. v. Naples Garden Inn, LLC (M.D. Fla. 2021).
C.S. v. Naples Hotel Co. (M.D. Fla. 2021).
S. Y. v. Naples Hotel Co. (M.D. Fla. 2021).
S.Y. v. Choice Hotels Int'l, Inc. (M.D. Fla. 2021).
S.Y. v. Inn of Naples Hotel, LLC (M.D. Fla. 2021).
S.Y. v. Holiday Hosp. Franchising, LLC (M.D. Fla. 2021).
C.S. v. Choice Hotels Int'l, Inc. (M.D. Fla. 2021).
C.S. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
C.S. v. Inn of Naples Hotel (M.D. Fla. 2021).
S.Y. v. Best W. Int'l, Inc. (M.D. Fla. 2021).
St. Martinus Univ., N.V. v. Caribbean Health Holding, LLC (S.D. Fla. 2020).
Hall v. Ins. Corp. of British Columbia (M.D. Fla. 2024).
Doe v. 4201 Orlando, Inc. (M.D. Fla. 2024).
Sanders v. Kerwin (M.D. Fla. 2024).
Jason Hartman v. Charles Sells (11th Cir. 2025).
Dorworth v. Greenberg (M.D. Fla. 2025).
Lawson v. Mulieri, 578 So. 2d 823 (Fla. 2d DCA 1991).
Black v. Brown, 812 So. 2d 581 (Fla. 3d DCA 2002).
Perlman v. Abel, 881 So. 2d 1156 (Fla. 4th DCA 2004).
S.Y. v. Sunstream Hotels & Resorts, LLC (M.D. Fla. 2021).
C.S. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
C.S. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
S.Y. v. Wyndham Hotels & Resorts, Inc. (M.D. Fla. 2021).
S.Y. v. Marriott Int'l, Inc. (M.D. Fla. 2022).
Schalamar Creek Mobile Homeowner's Ass'n, Inc. v. Adler (M.D. Fla. 2022). “Judge Porcelli specifically recommends that the Court find that Defendants are entitled to attorney’s fees pursuant to § 772.104(3), F.S. Judge Porcelli further recommends that Defendants be allowed to supplement their petition for taxation of costs upon filing their…”
Doe v. 4201 Orlando, Inc. (M.D. Fla. 2024).
S.M. v. 4201 Orlando, Inc. (M.D. Fla. 2024).
Doe v. 4201 Orlando, Inc. (M.D. Fla. 2024).
Ocean Commc'ns, Inc. v. The Jewelry Channel (S.D. Fla. 2020).
Fernau v. Enchante Beauty Prods., Inc. (S.D. Fla. 2021).
Ellingsworth Residential Cmty. Ass'n, In (Bankr. M.D. Fla. 2021).
Schenk v. Se. Banking Corp., 40 Fla. Supp. 2d 214 (Fla. Cir. Ct. 1990).
Dean Witter Reynolds, Inc. v. Toppino, 611 So. 2d 560 (Fla. 3d DCA 1992).
Ass'n of Sch. Consultants, Inc. v. Spillis Candela & Partners, Inc., 639 So. 2d 991 (Fla. 4th DCA 1994).
Capital Bank v. MVB, Inc., 683 So. 2d 1175 (Fla. 3d DCA 1996).
— 772.104(1) — 8 cases
Lockheed Martin Corp. v. Boeing Co., 314 F. Supp. 2d 1198 (M.D. Fla. 2004). “Criminal activity includes several predicate crimes named in section 772.104(1), Florida Statutes, and a “pattern of criminal activity” under the Florida RICO Act consists of engaging in at least two incidents of criminal activity that have the same or similar intents, results,…”
Bortell v. White Mountains Ins. Grp., Ltd., 2 So. 3d 1041 (Fla. 4th DCA 2009). “Section 772.104(1) provides, “Any person who proves by clear and convincing evidence that he or she has been injured by reason of any violation of the provisions of s.”
Eagletech Commc'ns, Inc. v. Bryn Mawr Inv. Grp., Inc., 79 So. 3d 855 (Fla. 4th DCA 2012). “Section 772.104(1) provides civil remedies for violations of section 772.”
Steve Ferguson v. the Repub. of Trinidad & Tobago (Fla. 3d DCA 2025). “§ 772.104(1), Fla. Stat. Florida Civil RICO’s substantive provisions provide it is unlawful for any person to use the proceeds “from a pattern of criminal activity.”
Steve Ferguson v. the Repub. of Trinidad & Tobago (Fla. 3d DCA 2025). “§ 772.104(1), Fla. Stat. Florida Civil RICO’s substantive provisions provide it is unlawful for any person to use the proceeds “from a pattern of criminal activity.”
Royal Palm Vill. Residents, Inc. v. Slider (M.D. Fla. 2021).
Ocean Commc'ns, Inc. v. The Jewelry Channel (S.D. Fla. 2020).
Ellingsworth Residential Cmty. Ass'n, In (Bankr. M.D. Fla. 2021).
— 772.104(3) — 4 cases
DJ Lincoln Enter., Inc. v. Google, LLC (S.D. Fla. 2022). “The Report and Recommendation cites well-reasoned caselaw standing for the proposition that achieving the dismissal with prejudice of a Florida RICO claim due to failure to state a claim does enable the defendant to collect attorneys’ fees under § 772.104(3). Plaintiff…”
Bahrakis v. Zimmerman (M.D. Fla. 2020). “Section 772.104(3) provides that a defendant is entitled to recover reasonable attorneys’ fees “upon a finding that the claimant raised a claim which was without substantial fact or legal support.”
Schalamar Creek Mobile Homeowner's Ass'n, Inc. v. Adler (M.D. Fla. 2022). “Judge Porcelli specifically recommends that the Court find that Defendants are entitled to attorney’s fees pursuant to § 772.104(3), F.S. Judge Porcelli further recommends that Defendants be allowed to supplement their petition for taxation of costs upon filing their…”
Eaton v. The Bank of New York Mellon (N.D. Fla. 2021). “Fee Entitlement under § 772.104(3), Florida Statutes.1 As noted above, Florida’s Civil Remedies for Criminal Practices Act mandates fees to a prevailing defendant where a plaintiff raises a claim without substantial fact or legal support.”
— 772.104(8) — 1 case
Fid. Warranty Servs., Inc. v. Firstate Ins. Holdings, Inc., 98 So. 3d 672 (Fla. 4th DCA 2012). “” §§ 772.104(8), 812.035(7), Fla. Stat. The trial court found that the directed verdict was sufficient to trigger JMA’s entitlement to fees under the statutes, but denied the motion for fees after JMA failed to isolate the attorney time spent on the civil theft counterclaim.”
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