A Florida court has reversed a decision that struck a provision allowing a landlord to seek attorney’s fees from tenants after a judgment was made in their favor. The ruling affects Taplin Falls, Ltd., and Taplin Meadows Development Corporation, who were seeking to collect attorney’s fees from Jason Brown and Genelle Gordon following a landlord-tenant dispute. This case highlights the importance of adhering to procedural rules when it comes to seeking legal fees.

The court's decision, issued on October 28, 2026, is significant because it clarifies the authority of trial courts to amend final judgments after they have been entered. It underscores the need for courts to follow established rules regarding the timing of motions for attorney's fees and costs.

In this case, Taplin Falls, Ltd., and Taplin Meadows Development Corporation, referred to collectively as Taplin Falls, filed an appeal against Jason Brown and Genelle Gordon after the trial court struck a provision from a final judgment that allowed Taplin Falls to file for attorney’s fees and costs within a specified period. The trial court had initially awarded Taplin Falls $10,233 in an uncontested landlord-tenant action and reserved the right to award attorney’s fees and costs. However, nearly three months after the judgment was entered, the trial court decided to strike the provision that allowed Taplin Falls an additional 45 days to file for those fees, claiming it was legally erroneous.

The dispute arose when Taplin Falls filed their motion for attorney’s fees exactly on the 45th day after the final judgment. The trial court, however, ruled that the motion was untimely due to the striking of the provision allowing for the extension. Taplin Falls argued that the trial court did not have the authority to modify the final judgment after the time for rehearing had expired, which led to the appeal.

The court ruled that the trial court's action to strike the provision was unauthorized. It stated, "A perceived error of law did not authorize the trial court to revise the final judgment after the time for rehearing had expired." The ruling emphasized that once a final judgment is rendered, the trial court's jurisdiction over the action is generally terminated, except for specific circumstances outlined by the Florida Rules of Civil Procedure.

The judges involved in the decision included KlingenSmith, Gerber, and Associate Judge Rebecca White. The court found that the trial court had acted beyond its authority by striking the provision and that Taplin Falls had timely filed its motion for attorney’s fees within the allowed period.

The court further explained that the trial court's authority to revise a final judgment is limited and that any substantive changes must follow specific procedural rules. The order striking the provision was deemed a substantive alteration, which the trial court could not make after the designated time had passed. Therefore, the court reversed the order that denied Taplin Falls’s motion for attorney’s fees and costs and instructed the trial court to reinstate the provision.

This ruling has implications for future landlord-tenant disputes in Florida, as it reinforces the importance of following procedural rules regarding the filing of motions for attorney’s fees. Landlords and tenants alike must be aware of the timelines and requirements for seeking legal fees to avoid complications in their cases.

The court's decision also serves as a reminder that trial courts must adhere to established legal standards and cannot make retroactive changes based solely on perceived errors in law. This ruling may set a precedent for similar cases in the future, ensuring that parties involved in legal disputes have a clear understanding of their rights and obligations regarding attorney’s fees.

Looking ahead, it is unclear whether this case will be appealed further. The court's ruling is not final until the disposition of any timely-filed motion for rehearing. If such a motion is filed, it could potentially alter the outcome of this case. However, as it stands, the ruling provides clarity on the authority of trial courts in Florida regarding the modification of final judgments and the filing of attorney’s fees motions.