Fee Award Cannot Exceed What Lawyer Actually Billed Client

In Effective Teleservices, Inc., et al v. Smith (4D08-1329), the Fourth District reversed, in part, the trial court's order because an award of attorney fees cannot exceed the amount actually billed to the client. The court cited "See Spagnolo v. Nicoletti, 755 So. 2d 671 (Fla. 4th DCA 1999) (holding it was error for the trial court to award attorney’s fees in an amount greater than what was charged to the client)."