Florida Litigation Procedure Update: Insights from AT&T Mobility v. Rigney on § 57.105

The recent update on Florida’s litigation procedure has sparked significant interest amongst legal professionals, with the Third District Court of Appeal (DCA) delivering clarity on key aspects of § 57.105 in AT&T Mobility, LLC v. Rigney. This case, calling for a review of the denial of two sanctions motions under section 57.105, featured noteworthy court rulings that were of great importance to litigators at both trial and appellate levels in Florida.

Firstly, the DCA did not simply make a blanket affirmation or denial of the trial court’s rulings. On the contradiction, the court reinforced one of the decisions but reaffirmed another. Such a “split-decision” approach insights careful consideration, especially for those eager to forecast potential outcomes in similar cases going forward.

Crucially, the verdict in AT&T Mobility v. Rigney sheds light on the intricacies of section 57.105, delving into the relationship between two primary provisions in said section, 57.105(1) and the good faith clause. This newfound understanding of these central provisions is necessary, serving as the genesis for precedents in the foreseeable future.

The information on Florida’s litigation procedure and precedent comes courtesy of Fuerst Ittleman David & Joseph. Although the Third DCA’s move was not extraordinary in legal practice, it fetched substantial visibility given its potential ramifications on future cases that involve application of § 57.105.

That being said, this development isn’t just important for existing and future cases under § 57.105 within Florida. It will also make waves in law textbooks, especially those focusing on the perpetually shifting landscape of litigation procedure, upping their relevance and value for both students and practicing litigators across the nation.