As a result, our analysis to the contrary in Holder no longer applies, and arguing on appeal that a committed person presented "sufficient" evidence cannot, standing alone, demonstrate error. See Cox v. Great Am. Ins. Co., 203 So. 3d 204, 205 (Fla. 4th DCA 2016) ("[O]n appeal the duty rests upon the appealing party to make error clearly appear." (citations omitted)).
Given the lack of proposed language, Appellant cannot demonstrate, error on appeal. See Cox v. Great Am. Ins. Co., 203 So. 3d 204, 205 (Fla. 4th DCA 2016) ("[O]n appeal[,] the duty rests upon the appealing party to make error clearly appear." (quoting Lynn v. City of Fort Lauderdale, 81 So. 2d 511, 513 (Fla. 1955))).
As such, Appellant has not carried her burden to demonstrate error on appeal. See Cox v. Great Am. Ins. Co., 203 So. 3d 204, 205 (Fla. 4th DCA 2016) ("[O]n appeal[,] the duty rests upon the appealing party to make error clearly appear." (quoting Lynn v. City of Fort Lauderdale, 81 So. 2d 511, 513 (Fla. 1955))).
USAA's standing argument on appeal is deficient because it fails to even acknowledge this assignment, let alone explain why the trial court's order denying USAA's motion to dismiss for lack of standing was in error or to otherwise explain why Mikrogiannakis lacks standing in light of the assignment. SeeCox v. Great Am. Ins. Co. , 203 So. 3d 204, 205 (Fla. 4th DCA 2016) ("[O]n appeal the duty rests upon the appealing party to make error clearly appear."
"[I]nterest accrues [on an award of attorney's fees] from the date the entitlement to attorney fees is fixed through agreement, arbitration award, or court determination, even though the amount of the award has not yet been determined." Bayview Loan Servicing, LLC v. Cross , 286 So. 3d 858, 863 (Fla. 5th DCA 2019) (alterations in original) (quoting Quality Eng'd Installation, Inc. v. Higley S., Inc. , 670 So. 2d 929, 930–31 (Fla. 1996) ); see alsoCox v. Great Am. Ins. Co. , 203 So. 3d 204, 206 (Fla. 4th DCA 2016) ("[A]ppellee was ... entitled to interest on the attorney's fees award from th[e] date entitlement was determined.") (citation omitted). Here, the county court's order granting the plaintiff's motion for entitlement to attorney's fees fixed such entitlement.
Accordingly, contemporary, binding jurisprudence dictates that interest accrues "from the date the entitlement to attorney fees is fixed through agreement, arbitration award, or court determination." Quality Engineered Installation, Inc. v. Higley S., Inc., 670 So. 2d 929, 930-31 (Fla. 1996) (citations omitted); see also Cox v. Great Am. Ins. Co., 203 So. 3d 204, 206 (Fla. 4th DCA 2016) ("[A]ppellee was also entitled to interest on the attorney's fees award from th[e] date entitlement was determined.") (citation omitted). Alternatively, if proof is adduced that fees were "incurred and paid" by a party "prior to the entry of judgment," prejudgment interest is proper.