In Standard Guar. Ins. Co. v. Quanstrom, 555 So. 2d 828 (Fla. 1990), the issue before the Court concerned the "setting of a reasonable attorney's fee under the lodestar approach and required a determination of whether a contingency fee multiplier must be utilized when determining the appropriate attorney's fee to be paid to a prevailing insured pursuant to section 627.428, Florida Statutes (1987)." 555 So. 2d at 829. The Quanstrom Court modified the contingency fee multiplier articulated in Rowe in response to two subsequent United States Supreme Court decisions. Id. at 830-33. To provide guidance in applying the contingency fee multiplier the Court noted: "Different types of cases require different criteria to achieve the legislative or court objective in authorizing the setting of a reasonable attorney's fee. . . . We find it appropriate to place attorney's fee cases into the following three categories: (1) public policy enforcement cases; (2) tort and contract claims; and (3) family law, eminent domain, and estate and trust matters. These categories are not intended to be all-inclusive." Id. at 833. The Court found it necessary to reexamine the principles adopted in Florida Patient's Compensation Fund v. Rowe, 472 So. 2d 1145, 1148 (Fla. 1985) regarding the federal lodestar approach and the use of the multiplier. The Court observed that federal courts had developed the lodestar method for determining attorney's fees to apply to a "special class of cases, in which Congress had enacted fee-authorizing statutes to pay fees to prevailing plaintiffs for the purpose of obtaining public enforcement of Congressional acts." Quanstrom, 555 So. 2d at 831. In Quanstrom the Court did not eliminate the consideration of a contingency risk multiplier in contract cases. Instead, the Court concluded that in tort and contract cases the multiplier is "a useful tool which can assist trial courts in determining a reasonable fee in this category of cases when a risk of nonpayment is established," while emphasizing that "the criteria and factors utilized in these cases must be consistent with the purpose of the fee-authorizing statute or rule." 555 So. 2d at 834.