Everman's Electric Company, Inc. v. J.J. Sosa & Associates, Inc., 1:14-cv-00440

Everman’s Electric obtained an arbitration award against J.J. Sosa & Associates, Inc.; Sosa moved for a federal judgment enforcing the award, plus interest, attorneys’ fees, and costs.
Everman objected only to the number of hours billed (nine total) claimed by Sosa’s counsel as excessive.
Sosa submitted an affidavit detailing attorneys’ experience, hourly rates, and tasks (research, correspondence, strategy meetings) and defended the nine hours as reasonable.
The arbitrator had awarded eight percent interest "from and after the date of the Award" but said nothing expressly about pre-judgment interest; Sosa sought eight percent post-judgment and pre-judgment interest.
Court reviewed fee affidavit, found hours and hourly rates reasonable, allowed attorneys’ fees; addressed distinction between arbitrator-awarded interest and statutory post-judgment interest under 28 U.S.C. § 1961.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonableness of claimed attorneys’ time	Nine hours is excessive given counsel’s experience	Nine hours included research, strategy, correspondence, and enforcement work and is reasonable	Court found nine hours reasonable and hourly rates consistent with the region; fees awarded
Effect of arbitrator’s award of 8% interest on post-judgment interest	(no separate position)	Arbitrator’s 8% award should control post-judgment interest	Court held arbitrator’s post-award interest does not control post-judgment interest; §1961 governs post-judgment rate
Appropriate post-judgment interest rate	—	Request for 8% post-judgment interest	Post-judgment interest limited to rate in 28 U.S.C. §1961 (Treasury yield), not 8%
Pre-judgment interest for period between award and judgment	Objected only to fees; not contesting pre-judgment interest	Requested 8% pre-judgment interest from award date to judgment date	Court awarded pre-judgment interest at arbitrator’s 8% rate for period from arbitration award to federal judgment (Mississippi law governs)

Tricon Energy Ltd. v. Vinmar Int’l, Ltd., 718 F.3d 448 (5th Cir. 2013) (distinguishes arbitrator-awarded post-award interest from federal post-judgment interest)
Executone Info. Sys., Inc. v. Davis, 26 F.3d 1314 (5th Cir. 1994) (state law governs pre-judgment interest on arbitrator awards)
Moeller v. Am. Guar. & Liab. Ins. Co., 812 So. 2d 953 (Miss. 2002) (pre-judgment interest may be awarded when principal is fixed prior to judgment)
McVay v. Halliburton Energy Servs., Inc., 688 F. Supp. 2d 556 (N.D. Tex. 2010) (awarding pre-judgment interest from arbitration award date to judgment date)