Background
Florida Peninsula Insurance Company appealed a trial court judgment in a Lee County case, challenging the court’s award of attorneys’ fees in favor of the appellees, SFR Services, LLC and individual defendants Stephen Johnson and Sheila Corbin. The trial court awarded the attorneys’ fees to the opposing parties but declined to include prejudgment interest in the judgment.
The Court’s Holding
The Sixth District Court of Appeal affirmed the trial court’s award of attorneys’ fees but reversed on the issue of prejudgment interest. The court held that prejudgment interest accrues when entitlement to a judgment is determined and becomes part of the total sum adjudged due and owing. When a date certain exists establishing entitlement, the trial court has a ministerial duty to compute the appropriate prejudgment interest and add it to the judgment.
The court found that the trial court erred by failing to award prejudgment interest and remanded the case for the trial court to enter an amended judgment that accounts for prejudgment interest calculations.
Key Takeaways
- Once entitlement to judgment is established, prejudgment interest automatically accrues and must be calculated and included in the final judgment.
- Trial courts have a mandatory, ministerial duty to compute and award prejudgment interest when a date certain for entitlement exists.
- Failure to award prejudgment interest constitutes reversible error even when other aspects of the judgment are affirmed.
Why It Matters
This decision reinforces that prejudgment interest is not discretionary but a mandatory component of damages calculations in Florida. Insurance companies and other litigants cannot secure complete relief if trial courts omit prejudgment interest from judgments, even when they correctly award other damages or fees.
The ruling clarifies that the appellate courts will closely scrutinize prejudgment interest calculations and will remand cases to correct omissions, ensuring that judgment creditors receive the full economic benefit of timely entitlement determinations.