Spaid v. 4-R Equipment, LLC

A trial court does not err by declining to award prejudgment interest when the jury does not resolve issues of fact with regard to the award of prejudgment interest, unless the pertinent facts were undisputed.

Spaid appealed the trial court's denial of prejudgment interest on a back pay award. The jury awarded Spaid $200,000 in back pay and benefits and $10,000 in noneconomic damages. The jury was not submitted the issue of whether Spaid could recover prejudgment interest and they made no findings of fact regarding that issue. The Court of Appeals held that a trial court does not err by declining to award prejudgment interest when the jury does not resolve issues of fact with regard to the award of prejudgment interest, unless the pertinent facts were undisputed. Since the amount Spaid would have made after his wrongful discharge and the length of time he would have worked were in dispute and the jury did not issue a special verdict regarding prejudgment interest, the trial court did not err by failing to award prejudgment interest. Affirmed.