Whether a party seeking an award of attorney fees needs an expert witness to testify in support of the reasonableness of the fees requested has been the subject of much discussion and many written legal opinions in Florida. The answer depends on the type of case, against whom fees are being sought, and in what area of the state the case is proceeding.

The general rule is that a party seeking an award of attorney fees from the other party to litigation must introduce the testimony of an expert witness in support of the request. Family law proceedings under Chapter 61 are a notable exception, as the statute expressly provides that expert testimony of a fee witness is unnecessary to seek an award of attorney's fees from the other side in proceedings under that chapter. The general rule requiring expert testimony appears to hold true when seeking fees in the same proceeding pursuant to a charging lien. See, Roshkind v. Machiela, 45 So.3d 480 (Fla. 4th DCA 2010). But things are more uncertain when an attorney seeks unpaid attorney fees from the attorney's own client or former client.