Florida Peninsula Insurance Company won just one point on appeal - but that point, on prejudgment interest, is one claims teams should note.
On June 19, 2026, Florida's Sixth District Court of Appeal ruled on the insurer's challenge to a trial court's attorneys' fees award. The case reached the court from the Circuit Court for Lee County. The opposing party was SFR Services, LLC, which appears in the case as an assignee under an assignment of benefits - an arrangement where a policyholder signs over the right to collect insurance money to a contractor or vendor.
According to the opinion, the fees had been awarded in Florida Peninsula's favor, and the insurer challenged that award. The appellate court affirmed the trial court "on all issues raised without comment, except one." That single exception is the story.
Florida Peninsula argued the trial court erred by failing to award prejudgment interest - the interest that builds up on money owed during the stretch before a judgment is entered. The appeals court agreed.
Leaning on a 2021 ruling, Lizardi v. Federated National Insurance Company, the court explained 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.'" In plain terms, once a court fixes the date one side becomes entitled to the money, adding the interest is treated as a routine step rather than a judgment call. Under the standard the court relied on, the trial court was obligated to perform its "ministerial duty of computing the appropriate amount and adding it to the judgment." The opinion pointed to two additional decisions backing the same approach.
So the court reversed on that point and sent the case back, instructing the trial court to enter "an amended award accounting for prejudgment interest."
For insurers and claims professionals, the practical signal is narrow but real. Where entitlement is fixed as of a date certain, the standard the court applied treats prejudgment interest as something the trial court must add, not a matter of discretion. Here, leaving it out was enough to reverse part of the ruling and send the award back, even though the rest of it stood. The takeaway is procedural, not dramatic, but it is the kind of detail that decides whether an award holds up.
The decision was issued per curiam, with Judges White and Smith and Associate Judge Netcher concurring. It is not yet final and can still face a motion for rehearing.
