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Attorney’s fees

Who Pays the Attorney’s Fees in a Florida Divorce

Florida has no rule that the wealthier party pays. It has a 2-part test, and a Supreme Court case that widened what a court may consider.

Erica G. Burns, Esq.·7 min read·Reviewed September 2026
Attorney’s fees September 2026

Section 61.16 permits a court, after considering the financial resources of both parties, to order one party to pay a reasonable amount for attorney’s fees, suit money and costs. It reaches enforcement proceedings, modifications and appeals.

The statute

The Florida Supreme Court has described the purpose of the section plainly: to ensure that both parties will have a similar ability to obtain competent legal counsel.

The test is need and ability to pay

Both prongs must be present. A party with genuine need whose counterpart can’t contribute will not receive an award. A party whose counterpart has significant resources but who has no actual need will not receive one either. You don’t have to be entirely unable to pay your own fees to qualify.

Rosen v. Rosen, and why every family lawyer cites it

In Rosen v. Rosen, 696 So. 2d 697 (Fla. 1997), the Supreme Court held that courts are not limited to financial resources when awarding fees under section 61.16. The statute should be construed liberally, to allow consideration of any factor necessary to provide justice and ensure equity between the parties.

Rosen directs courts to consider the scope and history of the litigation, its duration, the merits of the parties’ respective positions, whether a position was taken to harass, frustrate or delay, and the existence of prior or pending claims.

What that means in practice

Conduct matters A party who acts in bad faith, litigates excessively, or needlessly drives up costs may be ordered to pay fees.
It cuts both ways A lower-earning party who pursues senseless litigation to delay a case may find the higher-earning party is not required to cover those fees.
Equal ability, no award Where the parties have an equal ability to pay and no other Rosen equity is present, it is error to award either party fees from the other.
Substantial disparity Where a substantial disparity in income or assets exists and no other Rosen equity is present, it is error not to award fees.
Reasonableness Section 61.16 permits only a reasonable amount. Reasonableness applies to both fees and costs.

What this means for how you prepare

A fee award is not a plan. It is a possibility that depends on the other party’s resources, on your own need, and on how both sides conduct the case. It is also decided after the fees have already been incurred.

The expense a client controls is the work performed before and during the case. Identifying accounts, obtaining statements and assembling the mandatory disclosure require no law license. That work is billed at the office hourly rate when the office performs it.

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