Delmonico v. Crespo, 127 So. 3d 576

Delmonico sued Crespo and DMI for defamation, alleging Crespo's statements and vicarious liability by DMI.
Crespo admitted making the statements and settled; trial proceeded against DMI.
Jury rendered a verdict in favor of DMI, finding Delmonico not damaged by defamation.
DMI moved for attorney’s fees under Florida Statutes section 768.79 after the offer of judgment.
Trial court denied the original motion; on remand, it awarded fees for 1800–1900 hours and awarded $25,000 in expenses, with some expenses deemed nonrecoverable as overhead.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the fee award lacked specific hourly findings.	Delmonico	DMI	Reversed; remand for explicit hourly findings required.
Whether the $25,000 expense award was proper as a sanction under §768.79.	Delmonico	DMI	Reversed; none of the enumerated costs were taxable.

Florida Patient's Compensation Fund v. Rowe, 472 So.2d 1145 (Fla. 1985) (requires specific hourly-rate, hours, and adjustment findings)
Baratta v. Valley Oak Homeowners’ Ass’n at the Vineyards, Inc., 891 So.2d 1063 (Fla. 2d DCA 2004) (details required for fee determinations)
Highlands Carpentry Serv., Inc. v. Connone, 873 So.2d 611 (Fla. 2d DCA 2004) (final judgments must specify hours and rate)
In re Amendments to Uniform Guidelines for Taxation of Costs, 915 So.2d 612 (Fla. 2005) (guidelines on taxation of costs; non-testifying expenses not taxable)
Jorling v. Habilitation Servs., Inc., 2005 WL 1657060 (S.D. Ohio 2005) (jury consultant costs not recoverable)
Skidmore v. Dept. of Transp., 720 So.2d 1125 (Fla. 4th DCA 1998) (taxonomy of taxable costs; various routine expenses not recoverable)
C & S Chems. Inc. v. McDougald, 754 So.2d 795 (Fla. 2d DCA 2000) (non-taxable costs not recoverable under §768.79)