## Facts

- Harry and Jewell Hadley were injured in an automobile accident involving Helen Maxwell and her marital community.
- The Hadleys sued the Maxwells for negligence in Washington superior court.
- In June 1998, a jury found the Maxwells 100% at fault and awarded damages totaling $136,000 ($125,000 to Jewell Hadley and $11,000 to Harry Hadley).
- The trial court entered judgment on June 8, 1998, including postjudgment interest at 12% per year (as provided by statute for that judgment).
- The Maxwells appealed liability-related issues but did not seek review of the damages amounts.
- After review, the Washington Supreme Court reversed on a procedural liability issue involving collateral estoppel and remanded for a new trial limited to liability, noting the damages award had been fully litigated and was not challenged.
- In January 2003, the case was retried to a jury on liability only, and the jury again found the Maxwells solely liable.
- Following the 2003 liability verdict, the trial court entered judgment and awarded postjudgment interest only from the 2003 judgment date, not from June 8, 1998.
- The Hadleys appealed the interest ruling, arguing that interest should run from the original 1998 judgment date because damages had been fixed and never reopened.

## Issues

1. When an appellate remand orders a new trial limited to liability and leaves a prior damages award intact, does the damages portion remain a liquidated amount for purposes of postjudgment interest?
2. Under RCW 4.56.110(3), should postjudgment interest on the unchanged damages award run from the original 1998 judgment date rather than the later 2003 judgment entered after the liability-only retrial?

## Decision

- The Court of Appeals reversed the trial court’s decision limiting interest to the 2003 judgment date.
- The court held the Hadleys were entitled to postjudgment interest running from June 8, 1998, the date the original money judgment fixing damages was entered.
- The case was remanded for entry of a judgment that included interest accruing from the 1998 judgment date.

## Legal Principles

- A claim is liquidated when the amount due is fixed, certain, or capable of determination from the evidence and does not require further fact-finding on the amount.
- A dispute over one part of a claim (such as liability) does not make an otherwise fixed damages award unliquidated.
- Under RCW 4.56.110(3), interest on a tort money judgment runs from the date of entry of the judgment until it is satisfied.
- When an appellate court orders a retrial limited to liability and leaves the damages determination undisturbed, the original judgment fixing damages remains the operative money judgment date for calculating postjudgment interest.

## Conclusion

Because the amount of the Hadleys’ damages was determined in 1998 and was not challenged or reopened on remand, the damages award remained liquidated even though liability was retried in 2003; therefore, RCW 4.56.110(3) required postjudgment interest to accrue from the date of the original June 8, 1998 judgment rather than from the later post-remand judgment date.


Hadley v. Maxwell, 84 P.3d 286 (2004)