Edgardo Lebron v. Royal Caribbean Cruises LTD., 20-14449

Edgardo Lebron sued Royal Caribbean for negligence after an ice-skating rink accident that caused a serious ankle fracture; a jury awarded $625,000 for pain and suffering and $42,005.75 (later reduced) for past medical expenses, then apportioned 35% fault to Lebron, reducing the pain-and-suffering award to $406,250.
The jury verdict was a lump sum for pain and suffering; there was no jury instruction on prejudgment interest and no itemized verdict separating past and future damages.
After an appeal and remand, Lebron asked the district court for prejudgment interest on the pain-and-suffering award (initially on the whole award, later claiming 75% was past damages).
The district court awarded prejudgment interest only on past medical expenses, denied interest on the pain-and-suffering lump sum, and rejected Lebron’s 75% apportionment as arbitrary and unsupported.
Lebron moved for reconsideration; the court denied it, finding he failed to provide an objective method to apportion the lump-sum award between past and future pain.
Lebron appealed; the Eleventh Circuit reviewed for abuse of discretion and affirmed the district court’s judgment and denial of reconsideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused its discretion by denying prejudgment interest on a lump-sum pain-and-suffering award	Lebron: court should apportion the lump sum (he later proposed 75% for past pain) and award prejudgment interest on the past portion	Royal Caribbean: no basis to apportion post-verdict; no jury instruction or itemized verdict; prejudgment interest inappropriate for future damages	Affirmed. Court did not abuse discretion; Lebron failed to provide an objective apportionment method and did not request jury instruction/itemized verdict
Whether prejudgment interest may be awarded on future damages included in a lump-sum award	Lebron: lump sum contains past damages warranting interest	Royal Caribbean: prejudgment interest is not allowed for future damages	Held that prejudgment interest is inappropriate for future damages; court may award interest only on identifiable past damages

Reichert v. Chemical Carriers, Inc., 794 F.2d 1557 (11th Cir. 1986) (prejudgment interest inappropriate for future damages; district court not required to guess apportionment of lump-sum award)
Parker Towing Co. v. Yazoo River Towing, Inc., 794 F.2d 591 (11th Cir. 1986) (standard of review: abuse of discretion for prejudgment interest decisions)
Deakle v. John E. Graham & Sons, 756 F.2d 821 (11th Cir. 1985) (after verdict, it may be too late to fix how damages were calculated or proved; courts should not rely on appellate fact-sorting)
Pickle v. Int'l Oilfield Divers, Inc., 791 F.2d 1237 (5th Cir. 1986) (prejudgment interest not available on future damages)
McDill v. VSSI Tokyo, Inc., 920 F. Supp. 727 (S.D. Tex. 1996) (district court noting potential unfairness of denying interest due to counsel oversight, but recognizing limits on court’s duty to correct errors)
Federal Trade Comm'n v. WV Universal Mgmt., 877 F.3d 1234 (11th Cir. 2017) (abuse-of-discretion framework explained)