Postjudgment Interest Due on Prejudgment Interest

Quality Engineered Installation, Inc. v. Higley S., Inc., 670 So.2d 929 (Fla. 1996) resolved a conflict among the Florida District Courts of Appeal and held that an award of prejudgment interest merges into and becomes part of a single total sum adjudged to be due and owing and as such the amount awarded for prejudgment interest, like all other components of the judgment, automatically bears interest as provided by section 55.03, Florida Statutes. The Florida Third District Court of Appeals, in Westport Recovery Corp. vs. Batista, 32 Fla.L.Weekly D2173 (Fla. 3rd. DCA 2007) applied the Quality Engineered decision and held that a writ of execution on a judgment had not been fully paid as the Sheriff had not collected postjudgment interest due on the awarded prejudgment interest. The Third District Court of Appeal also held that the Quality Engineered decision applies retroactively.