Prejudgment Interest applies to Awards for Unjust Enrichment or Quantum Meruit

In a recent case, a jury rendered a verdict in favor of a plaintiff for unjust enrichment. The trial court thereafter awarded prejudgment interest from the date of the jury's verdict. An issue on appeal was whether the prejudgment interest should have been awarded from the date of the plaintiff’s loss instead of the (later) date of the jury’s verdict. The appellate court held that the prejudgment interest should have been from the date of the loss as the record demonstrated when the date of loss occurred. In making this holding, the appellate court explained: A plaintiff is entitled to prejudgment...