Plaintiffs, successful litigants in Open Public Records Act litigation against defendant school district, obtained an order of judgment awarding attorney's fees on August 28, 2020. After the court affirmed the August 28, 2020 order of judgment, the parties failed to negotiate payment of the attorney's fees. Plaintiffs then sought a judgment for the attorney's fees in the Civil Judgment and Order Docket, which was entered on July 20, 2022. When plaintiffs sought to enforce the July 20, 2022 judgment against defendants, including payment for post-judgment interest, the trial court ordered post-judgment interest be calculated from July 20, 2022 to August 29, 2022, the date of its order. Plaintiffs appealed.
On appeal, the court held that post-judgment interest accrues from the date of a trial court's entry of an order of judgment awarding attorney's fees pursuant to Rule 4:47, rather than the date the judgment was docketed. Although the accrual date may be modified by the trial court in the interests of equity, there was no factual predicate proffered by defendants to support modification of the post-judgment interest accrual date in the record. Accordingly, the court reversed the August 29, 2022 order as to the accrual date of post-judgment interest and remanded to the trial court for entry of an order awarding post-judgment interest accruing from August 28, 2020.