FLORIDA PENINSULA INSURANCE COMPANY
v.
SFR SERVICES, LLC A/A/O STEPHEN JOHNSON AND SHEILA CORBIN
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When a trial court determines entitlement to damages on a date certain, it has a ministerial duty to compute and award prejudgment interest as part of the judgment.
[1] When a trial court determines entitlement to damages on a date certain, prejudgment interest accrues from that date and becomes part of the total sum adjudged due, and th…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The Florida Supreme Court holds that prejudgment interest begins to accrue when entitlement is determined and it 'becomes part of a single total sum adjudged to be due and owing.'”
Court's explanation of the legal standard for prejudgment interest, citing Lizardi v. Federated Nat'l Ins. Co.
Florida Peninsula Insurance Company appealed a trial court judgment in Lee County that awarded attorneys' fees but failed to include prejudgment inter…
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SIXTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
Case No. 6D2024-2213 Lower Tribunal No. 2019-CA-001292
FLORIDA PENINSULA INSURANCE COMPANY, Appellant,
V.
SFR SERVICES, LLC a/a/o STEPHEN JOHNSON and SHEILA CORBIN, Appellees.
Appeal from the Circuit Court for Lee County. Michael T. McHugh, Judge.
June 19, 2026
PER CURIAM.
Appellant Florida Peninsula Insurance Company challenges the trial court's award of attorneys' fees in its favor. We affirm on all issues raised without comment, except one.
We agree with Appellant that the trial court erred when it failed to award prejudgment interest. Lizardi v. Federated Nat'l Ins. Co., 322 So. 3d 184, 191 (Fla. 2d DCA 2021) (“The Florida Supreme Court holds that prejudgment interest begins to accrue when entitlement is determined and it 'becomes part of a single total sum
adjudged to be due and owing.' . . . [if] there was a date certain as to the issue of entitlement, and the trial court was obligated to perform its ministerial duty of computing the appropriate amount and adding it to the judgment."); see also El Brazo Fuerte Bakery 2 v. 24 Hour Air Serv., Inc., 330 So. 3d 552, 559 (Fla. 4th DCA 2021); Laird v. Miao, 427 So. 3d 669, 669 (Fla. 5th DCA 2026). We therefore reverse and remand on this point for the trial court to enter an amended award accounting for prejudgment interest.
AFFIRMED in part, REVERSED in part, and REMANDED with instruction.
WHITE and SMITH, JJ., and NETCHER E.J., Associate Judge, concur.
Jesse Dyer and Hinda Klein, of Conroy Simberg, Hollywood, for Appellant.
Melissa A. Giasi, of Giasi Law, P.A., Tampa, for Appellees.
NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING
AND DISPOSITION THEREOF IF FILED
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Citator
Authorities Cited
- Misael Gomez Lizardi and Tanya Torres Gomez v. Federated Nat'l Ins. Co., 322 So. 3d 184 (Fla. 2d DCA 2021)