Public Health Trust/Jackson Memorial Hospital v. Spencer

Jackson Memorial Hospital/Publie Health Trust, and its servicing agent, Miami-Dade County, Risk Management Division (hereafter collectively referred to as “appellants”), appeal a final order granting prejudgment interest on an attorney fee award in a rule nisi proceeding enforcing a workers’ compensation order. We reverse finding there is no entitlement to prejudgment interest on an attorney fee award in a workers’ compensation proceeding until the amount of the fee has been approved.

In March of 1999, a workers’ compensation order on appeal was affirmed in favor of appellee, Constance Spencer…