Brinda Coates v. R.J. Reynolds Tobacco Company

Summary

The court held that Florida's offer-of-judgment statute is not a prevailing-party statute because its text authorizes fees as a penalty for rejecting a qualifying settlement proposal even when the fee applicant did not prevail in the proceeding. The court provisionally granted Coates' request for reasonable appellate attorney's fees, subject to the trial court's determination of entitlement and amount under the statute.