## Facts

- A collision between a vehicle driven by Lattermore Belcher and a tractor-trailer operated by a Woodline Motor Freight employee caused the truck to leave the roadway and crash into a convenience store and gas station.
- The store building and contents were essentially destroyed; Troutman Oil owned the property, and Jerry Crosland leased and operated the business.
- Troutman Oil sought damages for physical loss to the building and for lost profits; Crosland sought damages for destroyed property (including inventory) and for lost profits.
- Evidence on the amount of physical damage was contested, including competing expert views on whether the structure required total replacement, partial demolition and rebuilding, or repair, with widely varying cost estimates.
- Crosland supported inventory losses with a handwritten list valuing items based largely on his own estimates rather than invoices or formal inventory records.
- The jury allocated fault 80% to Belcher and 20% to Woodline, and awarded both plaintiffs property damages and lost profits.
- After a separate hearing, the trial court awarded 6% prejudgment interest on the property-damage portions (but not lost profits) from the date of the accident to the judgment date.
- Woodline and Belcher appealed only the prejudgment-interest award.

## Issues

1. Whether prejudgment interest may be awarded on property-damage verdicts when the amounts were disputed and not determinable by fixed standards at the time of the loss.
2. Whether availability of prejudgment interest in Arkansas turns on the case being in contract versus tort, or instead on a single ascertainability standard.

## Decision

- The Arkansas Supreme Court reversed the prejudgment-interest awards and otherwise left the judgment intact.
- The court held the property damages were not liquidated and not definitely ascertainable at the time of loss because the amounts depended on choosing among competing opinions and discretionary valuations.
- The court rejected a tort–contract distinction for prejudgment interest and applied a unified “definitely ascertainable” test.

## Legal Principles

- Prejudgment interest is allowed only when damages are definitely ascertainable by mathematical computation, or when the proof supplies data permitting computation without reliance on opinion or discretion.
- The dispositive inquiry is whether a method existed to fix the exact value of the claim at the time of the occurrence giving rise to liability.
- The ascertainability standard applies uniformly, without regard to whether the underlying claim sounds in tort or contract.
- If damages satisfy the ascertainability standard, prejudgment interest is recoverable as a matter of law; if not, it is unavailable.

## Conclusion

Because the building and inventory losses required factfinder judgment among contested repair/replacement approaches and subjective valuation, the property damages were not fixed or objectively computable at the time of the accident, so prejudgment interest was improper and was vacated while the underlying verdict remained in place.


Woodline Motor Freight, Inc. v. Troutman Oil Co., 327 Ark. 448 (1997)