Background
Snap! Mobile sued Vertical Raise and Paul Landers for tortious interference, trade-secret misappropriation, and unfair competition. After a damages trial, the jury awarded Snap $750,000 in unjust-enrichment damages and $250,000 in punitive damages. The district court incorrectly entered an October 2021 judgment totaling $800,000, then entered a December 2021 amended judgment that added discretionary costs and an additur.
In an earlier appeal, the Idaho Supreme Court affirmed the costs award, reversed the additur-or-new-trial ruling, and directed the district court to reinstate the jury’s $1 million verdict. After remittitur, Vertical Raise’s surety paid the $1 million verdict and costs but did not pay post-judgment interest. The district court ruled that interest on the original $800,000 award ran from October 15, 2021, and interest on costs ran from December 14, 2021, then entered a Third Amended Judgment.
The Court’s Holding
The Idaho Supreme Court affirmed. Idaho Code section 28-22-104(2) requires interest on money due under judgments and does not limit interest to a single final, appealable judgment. An amended judgment does not automatically nullify an earlier judgment for purposes of post-judgment interest.
Because the original $800,000 damages award was not reversed, interest on that amount began when the Original Judgment was entered. Likewise, because Snap’s discretionary costs award was affirmed in the first appeal, interest on those costs began when the Amended Judgment was entered. The Court declined to decide the parties’ dispute over the precise calculation of interest because that issue was not properly presented on appeal. It awarded Snap attorney fees because Vertical Raise pursued the appeal unreasonably and without foundation.
Key Takeaways
- Post-judgment interest may run from an original judgment even when a later amended judgment is entered.
- Interest runs from the original judgment date for amounts that remain intact after appeal.
- Arguments about interest calculations must be properly raised and supported to receive appellate review.
Why It Matters
The decision confirms that a judgment debtor cannot avoid interest on an undisputed, liquidated portion of a judgment merely because later proceedings amend the judgment or alter other components of the award. Parties seeking to stop interest from accruing should consider tendering the amount that is due rather than waiting for appellate proceedings to conclude.