DeSalvo sued Scottsdale Insurance Co. over a disagreement on the amount owed under an insurance policy covering a building that had burned. Scottsdale paid a lower amount than DeSalvo requested, but later offered to settle any further claims for $100,001. DeSalvo proceeded to trial and won an award less than this offer, $84,133.92. A "prevailing party's" attorney's fee and other costs usually would be paid in cases like this, but there is an exception if the recovery at trial is less than an amount offered in settlement. The trial court found that the case fell within the exception, but the First District reversed. It said the offer of $100,001 expressly included attorney's fees and costs. Thus, it held that the trial court needed to determine total fees and costs and subtract them from the $100,001 to determine who actually prevailed.