Lyantie Townsend, etc. v. R.J. Reynolds Tobacco Company
192 So. 3d 1223
| Fla. | 2016Background
- In April 2010 Townsend obtained a judgment (compensatory and punitive) that on its face provided post-judgment interest at 6% from April 29, 2010.
- Section 55.03(3), Fla. Stat. (2010) then provided: "The interest rate established at the time a judgment is obtained shall remain the same until the judgment is paid."
- After appeal and remittitur an amended final judgment was entered in 2012; interest was treated as accruing from the original April 29, 2010 date.
- In 2011 the Legislature amended §55.03 to move from a fixed rate to an annually (later quarterly) adjustable statutory rate (effective July 1, 2011).
- R.J. Reynolds sought a trial-court ruling that the 2011 amendment governed interest after July 1, 2011; the trial court denied relief, the First DCA reversed and certified a question to the Florida Supreme Court.
- The Florida Supreme Court held the 2010 statute created a vested substantive right to a fixed rate for judgments obtained while that statute was in effect, so the 2011 amendment cannot be applied retroactively to Townsend’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the 2011 amendment to §55.03(3) apply to judgments entered between Oct. 1998 and June 30, 2011? | Townsend: No — 2010 §55.03(3) fixed the interest rate for the life of any judgment obtained while it was in effect, creating a vested right. | R.J. Reynolds: Yes — common-law default rule means statutory rates change as Legislature changes rates; no vested right to future (unaccrued) interest. | No — the Court held the 2010 statute created a vested right to a fixed rate and the 2011 amendment cannot be applied to such judgments. |
| Did the 1998/2010 enactment of §55.03(3) abolish the common-law default rule? | Yes: the explicit statutory language that the rate "shall remain the same" superseded the common-law rule. | No: common-law rule should control absent clear legislative intent. | Yes: the statute’s text defeated the common-law default rule. |
| Is the 2010 §55.03(3) substantive or procedural (i.e., can it be applied retroactively)? | Substantive: it prescribes a legal right/obligation (certainty of fixed rate) and thus vests. | Procedural/remedial: changes to how interest is calculated are administrative and may apply to continuing judgments. | Substantive: the Court held the statute created vested substantive rights protected by due process. |
| When does the right to a fixed rate vest? | Townsend: At the moment the judgment is obtained (April 29, 2010), even if interest will accrue in the future. | R.J. Reynolds: Only to interest accrued before the 2011 amendment; no vested right in future unaccrued interest. | Vested when the judgment was obtained; remittitur relates amended judgment back to original date. |
Key Cases Cited
- Maronda Homes, Inc. of Florida v. Lakeview Reserve Homeowners Ass’n, 127 So.3d 1258 (Fla. 2013) (explaining vested-rights due-process limits on retroactive statutes)
- Scott v. Williams, 107 So.3d 379 (Fla. 2013) (distinguished; concerns future pension benefits and preservation statutes)
- Smith v. Goodpasture, 189 So.2d 265 (Fla. 4th DCA 1966) (remittitur: amended judgment relates back to original entry for post-judgment interest)
- Morley v. Lake Shore & M.S. Ry. Co., 146 U.S. 162 (U.S. 1892) (common-law default rule: statutory interest rates change with legislative changes)
- Thornber v. City of Ft. Walton Beach, 568 So.2d 914 (Fla. 1990) (statute supersedes common law when irreconcilable)
- Daniels v. Florida Dept. of Health, 898 So.2d 61 (Fla. 2005) (de novo review for statutory interpretation)
- Trinidad v. Florida Peninsula Ins. Co., 121 So.3d 433 (Fla. 2013) (plain statutory language controls interpretation)
- Metropolitan Casualty Ins. Co. v. Tepper, 2 So.3d 209 (Fla. 2009) (use ordinary definitions and avoid rendering statutory words superfluous)