Wilson v. State
2017 Ark. App. 553
| Ark. Ct. App. | 2017Background
- Regina Wilson obtained a jury verdict under the Arkansas Whistle‑Blower Act for $127,000 in November 2015; the circuit court entered judgment on December 3, 2015 stating the verdict "plus attorney’s fees, if any, and costs" and that all would bear 10% interest until paid.
- Wilson applied for attorney’s fees and costs on December 30, 2015, requesting $214,305 in fees and $19,987.49 in costs; the State contested reasonableness.
- On April 22, 2016, the circuit court awarded $201,250 in attorney’s fees and $3,009.81 in costs (quantifying the fee award).
- The State paid sums that it said satisfied principal and interest on the verdict and the principal of the fee/cost award, but a dispute remained whether postjudgment interest on the attorney’s‑fee award accrued from the December 2015 judgment date or from the April 22, 2016 fee‑quantification date.
- The circuit court ruled that interest on fees and costs accrues only after the amount is fixed by final order (i.e., from April 22, 2016), granted the State’s motion to compel satisfaction of judgment, and Wilson appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When does statutory postjudgment interest on attorney’s fees begin to run? | Interest should run from the date of the original judgment that established the right to fees (Dec. 3, 2015); relies on Mothershead/Glover and equitable concerns. | Interest runs only after the fee amount is quantified by final order (Apr. 22, 2016); earlier judgment did not fix dollar amount. | Interest accrues when the fee award is quantified in dollars and cents; court affirmed accrual from Apr. 22, 2016. |
Key Cases Cited
- Mothershead v. Douglas, 221 Ark. 756 (1953) (held postjudgment interest on an affirmed-as-modified judgment accrues from the original judgment date)
- Glover v. Woodhaven Homes, Inc., 346 Ark. 397 (2001) (reaffirmed Mothershead principle regarding interest after appellate modification)
- Daniel v. Arkansas Department of Human Services, 2017 Ark. 206 (2017) (held postjudgment interest on attorney’s‑fee awards accrues when fees are quantified in dollars and cents)