Florida's Third District Court of Appeal on Wednesday affirmed in part, reversed in part and remanded with directions a final judgment involving the plaintiff-appellees, attorney Kenneth B. Schurr and the Law Offices of Kenneth B. Schurr, and the defendant-appellant, attorney Daniel Kaplan.

In doing so, Ed Mullins, a partner at Reed Smith and attorney fees expert, observed that the decision centers around the difference between civil and criminal contempt. He noted that the plaintiff paid his counsel, Raymond Rafool, legal fees to prosecute, at the court’s appointment, the criminal contempt proceedings for not complying with the order. The court ruled that the fees were not chargeable to the plaintiff.