Daniel v. Arkansas Department of Human Services (Majority)Annotate this Case
Statutory postjudgment interest on attorney’s fees accrues when the fees were actually quantified in dollars and cents rather than when the right thereto was first established.
Plaintiff was granted judgment on her claim for retaliation under the Arkansas Whisteblower Protection Act. The circuit court entered judgment “plus costs and reasonable attorney’s fees to be determined by the court.” Three months later, the court entered a second order quantifying attorney’s fees. Defendant paid postjudgment interest on the attorney’s fees from the date that the award was entered. Plaintiff argued that she was entitled to attorney’s fees when the underlying judgment was entered. The circuit court granted the Department’s motion to compel entry of complete satisfaction. The Supreme Court affirmed, holding that postjudgment interest on an attorney’s-fee award accrues from the order setting the fee amount in dollars and cents.