Civil Procedure – Post-Judgment Interest

This case concerns how post-judgment interest in a civil lawsuit is calculated in a jurisdiction, the District of Columbia, where by statute the interest rate varies with a published quarterly rate by the Internal Revenue Service for tax underpayments. The appellee argued for a rate fixed at the time of the judgment, while appellant argued for a varying rate throughout the course of any post-judgment period, using whatever posted rate was in effect for that quarter. In this decision, the D.C. Court of Appeals reversed a trial court for abuse of discretion in its decision to reduce the award of interest to a successful medical malpractice plaintiff to an amount based on a rate of interest fixed at the time of judgment, when the interest rate published by the IRS was much lower than when the original appeal was ultimately resolved and payment of the principal was made.