Prejudgment Interest from the Date of the Loss or the Accrual of Cause of Action
In Jackson Grain Co. v. Hoskins, 75 So. 2d 306, 310 (Fla. 1954), the court explained that the reason for not allowing prejudgment interest from the date of loss in personal injury actions was that "an exception to the allowance of interest has been made in personal injury cases because of the speculative nature of some items of damage, such as mental anguish, and the indefiniteness of items such as future pain and suffering." Amerace, 823 So. 2d at 116 (Pariente, J., dissenting) (quoting Jackson, 75 So. 2d at 310).
"Thus, it has long been the law in Florida that in contract actions, and in certain tort cases, once the amount of damages is determined, prejudgment interest is allowed from the date of the loss or the accrual of cause of action." Id. at 116 (citing Jackson, 75 So. 2d at 310; Zorn v. Britton, 120 Fla. 304, 162 So. 879, 880 (Fla. 1935)).
In all cases, either of tort or contract, where the loss is wholly pecuniary, and may be fixed as of a definite time, interest should be allowed as a matter of right, whether the loss is liquidated or unliquidated. . . the plaintiff will not be fully compensated unless he receive, not only the value of what he has lost, but receive it as nearly as may be as of the date of his loss. William B. Hale, the Law of Damages, 67 (2d ed. 1912).