(Laws 1845, Cobb's 1851 Digest, p. 394; Code 1863, § 2027; Code 1868, § 2028; Code 1873, § 2054; Code 1882, § 2054; Civil Code 1895, § 2882; Civil Code 1910, § 3432; Code 1933, § 57-108; Ga. L. 1980, p. 1118, § 1; Ga. L. 1986, p. 195, § 1; Ga. L. 1987, p. 352, § 1; Ga. L. 1989, p. 14, § 7; Ga. L. 2003, p. 820, § 1.)
Cross references.- Amount of judgment upon which interest may be charged, § 9-12-10.
Pre-judgment interest in highway condemnation proceedings, § 32-3-19.
Code Commission notes.- Pursuant to Code Section 28-9-5, in 1988, the hyphen was deleted in the word "postjudgment" in subsection (c).
Pursuant to Code Section 28-9-5, in 2003, "July 1, 2003" was substituted for "the effective date of this Code section" in subsection (d).
Editor's notes.- Ga. L. 2003, p. 820, § 9, not codified by the General Assembly, provides that this Act "shall apply to all civil actions filed on or after July 1, 2003."
Law reviews.- For article discussing methods of computation of finance charges in Georgia consumer credit contracts, see 30 Mercer L. Rev. 281 (1978). For annual survey of trial practice and procedure, see 56 Mercer L. Rev. 433 (2004). For note on the 2003 amendment to this Code section, see 20 Ga. St. U.L. Rev. 28 (2003).
JUDICIAL DECISIONSANALYSIS
Construction with O.C.G.A. § 51-12-14. - Trial court did not err in adding interest to the award before considering whether the judgment was greater than the demand for purposes of O.C.G.A. § 51-12-14, as § 51-12-14 had to be construed in pari materia with O.C.G.A. § 7-4-12; post-judgment interest continued to accrue under § 7-4-12 until the set-off became effective under O.C.G.A. § 9-13-75. Sec. Life Ins. Co. v. St. Paul Marine & Fire Ins. Co., 263 Ga. App. 525, 588 S.E.2d 319 (2003).
Interest on judgments mandatory.
- See Gunnin v. Parker, 198 Ga. App. 864, 403 S.E.2d 822, cert. denied, 198 Ga. App. 897, 403 S.E.2d 822 (1991).
Judgment is a liquidated demand of highest dignity upon which creditor is entitled to interest. Executrix of Houston v. Mossman, 1 Ga. Rpt. Ann. (T.U.P.C. 138) 50 (1807).
Judgment for sum certain required.
- Mandate of O.C.G.A. § 7-4-12 that judgments bear interest "upon the principal amount recovered..." presupposes the rendition of a judgment of a sum certain; thus, in an action seeking declaration of the value of a homeplace equity that was not established at the time of a divorce judgment, the former wife was entitled to interest from the date of the declaratory judgment, not from the date of entry of the divorce judgment. Brown v. Brown, 265 Ga. 725, 462 S.E.2d 609 (1995).
Trial court did not err in denying a request for post-judgment interest since no judgment for a sum certain was entered. McClure v. Raper, 277 Ga. 642, 594 S.E.2d 330 (2004).
Retroactivity of increase.
- The 1980 amendment, which raised the interest on judgments from 7 percent to 12 percent, applied, as of July 1, 1980 (the effective date of the amendment), to judgments rendered before the effective date of the amendment but not satisfied by then. Shook & Fletcher Insulation Co. v. Central Rigging & Contracting Corp., 684 F.2d 1383 (11th Cir. 1982). But see DOT v. Delta Mach. Prods. Co., 162 Ga. App. 252, 291 S.E.2d 104 (1982); Camellia Corp. v. Cornell, 162 Ga. App. 362, 291 S.E.2d 556 (1982).
Application by federal court.
- Federal district court used an interest rate of 12% based on O.C.G.A. § 7-4-12, in computing the total amount of damages in an action for retirement benefits under the federal Employee Retirement Income Security Act, 29 U.S.C. § 1051 et seq. Williams v. Wright, 783 F. Supp. 1392 (S.D. Ga. 1992).
If forfeiture provision of
§ 7-4-10(a) applicable, judgment bears no interest. - If usurious interest was reserved for a loan of money, and in suit by lender against the debtor, the judgment was rendered for the principal amount only, interest being forfeited by virtue of Acts 1916, p. 48 (see now O.C.G.A. § 7-4-10(a)), such judgment bears no interest as that Act prohibited recovery of any interest if usury was charged. Tennille Banking Co. v. Quinn, 156 Ga. 159, 118 S.E. 644 (1923).
Commercial accounts.
- Commercial account is not, by virtue of O.C.G.A. § 7-4-16, regarding when interest runs on commercial accounts, transformed into such an "obligation" as would come within the exception to the standard post-judgment interest rate of 12 percent per year that is established by O.C.G.A. § 7-4-12. ADC Constr. Co. v. Hall, 202 Ga. App. 119, 413 S.E.2d 522 (1991).
Section applicable in action upon revolving account.
- Although general usury statutes are inapplicable to revolving accounts, those statutes do apply to interest rates chargeable on judgments for actions on such accounts. Farmers Mut. Exch. of Wrens, Inc. v. Rabun, 145 Ga. App. 798, 245 S.E.2d 52 (1978).
In proceeding to hold party in contempt for failure to make alimony and child-support payments under a divorce decree, the contempt judgment bears interest of 12 percent from the date of the judgment's entry. The court is vested with discretion in determining whether any interest is payable on the child-support arrearages prior to entry of the contempt judgment, which interest should be made part of the contempt judgment itself. Turner v. Turner, 251 Ga. 435, 306 S.E.2d 650 (1983); Leroux v. Avera, 192 Ga. App. 210, 384 S.E.2d 274 (1989).
Judgment against surety on supersedeas bond bears interest.
- Judgment in alimony suit against surety upon supersedeas bond given by the defendant for eventual condemnation money may, when remittitur from appellate court is received, affirming judgment, be rendered for full amount of all accrued unpaid installments due at time of entering of judgment, which necessarily represents eventual condemnation money. Such a judgment bears interest under former Civil Code 1910, § 3432 (see now O.C.G.A. § 7-4-12). Luke v. Luke, 32 Ga. App. 738, 124 S.E. 556 (1924).
Judgment providing for interest on interest is erroneous. State Hwy. Dep't v. Godfrey, 118 Ga. App. 560, 164 S.E.2d 340 (1968).
Cited in Sherwood v. Moore, 35 F. 109 (N.D. Ga. 1888); Sharpe v. City of Waycross, 185 Ga. 208, 194 S.E. 522 (1937); Shedden v. National Florence Crittenton Mission, 191 Ga. 428, 12 S.E.2d 618 (1940); Bank of Tupelo v. Collier, 192 Ga. 409, 15 S.E.2d 499 (1941); Fried v. Morris & Eckels Co., 118 Ga. App. 595, 164 S.E.2d 732 (1968); State Hwy. Dep't v. Owens, 120 Ga. App. 647, 171 S.E.2d 770 (1969); Giant Peanut Co. v. Carolina Chems., Inc., 135 Ga. App. 597, 218 S.E.2d 305 (1975); Laminoirs-Trefileries-Cableries de Lens, S.A. v. Southwire Co., 484 F. Supp. 1063 (N.D. Ga. 1980); FDIC v. Kucera Bldrs., Inc., 503 F. Supp. 967 (N.D. Ga. 1980); Pettigrew v. Houston's Bldg. Materials & Supply Co. (In re Guevara), 67 Bankr. 982 (Bankr. N.D. Ga. 1986); Camellia Corp. v. Cornell, 157 Ga. App. 625, 278 S.E.2d 168 (1981); Swish Mfg. S.E., Inc. v. Wilkie, 158 Ga. App. 275, 279 S.E.2d 724 (1981); DOT v. Cochran, 160 Ga. App. 583, 287 S.E.2d 599 (1981); Upton v. Duck, 249 Ga. 267, 290 S.E.2d 92 (1982); Stinson v. Georgia Dep't of Human Resources Credit Union, 171 Ga. App. 303, 319 S.E.2d 508 (1984); Bowers v. Price, 171 Ga. App. 516, 320 S.E.2d 211 (1984); Stuckey Health Care, Inc. v. State, 193 Ga. App. 771, 389 S.E.2d 349 (1989); Nodvin v. West, 197 Ga. App. 92, 397 S.E.2d 581 (1990); Hughes v. Great S. Midway, Inc., 265 Ga. 94, 454 S.E.2d 130 (1995); Threatt v. Forsyth County, 262 Ga. App. 186, 585 S.E.2d 159 (2003); Schoenbaum Ltd. Co., LLC v. Lenox Pines, LLC, 262 Ga. App. 457, 585 S.E.2d 643 (2003); Interfinancial Midtown, Inc. v. Choate Constr. Co., 343 Ga. App. 793, 806 S.E.2d 255 (2017); Adventure Motorsports Reinsurance v. Interstate Nat'l Dealer Servs., Ga. App. , 846 S.E.2d 115 (2020).
Rates
Legal interest rates are prima-facie "equitable" and any award deviating from the legal rates must be based upon sufficient evidence demonstrating that another rate is appropriate. Atlantic States Constr., Inc. v. Beavers, 169 Ga. App. 584, 314 S.E.2d 245 (1984).
Rate of interest.
- Generally interest on a judgment is to be calculated at seven percent (now 12 percent) per annum from date of judgment until payment, but when contract or note upon which action is based specifies a different rate, or when interest is prescribed by statute, the judgment thereon bears interest from the date of judgment at contract rate or at statutory rate. Chilivis v. Rogers Oil Co., 135 Ga. App. 176, 217 S.E.2d 179 (1975).
District court did not abuse the court's discretion in looking to the state statutory interest rate for guidance in determining the appropriate pre-judgment interest rate. Smith v. American Int'l Life Assurance Co., 50 F.3d 956 (11th Cir. 1995).
Director was properly awarded 12 percent interest on a lost wages award as lost wages were not open accounts under O.C.G.A. § 7-4-2. Gallagher v. McKinnon, 273 Ga. App. 727, 615 S.E.2d 746 (2005).
Trial court properly ordered that a judgment in favor of the plaintiffs in a personal injury action would bear post-judgment interest at a rate of 12 percent because the version of O.C.G.A. § 7-4-12 which was in effect at the time of the filing of the action allowed that rate of interest. Ford Motor Co. v. Sasser, 274 Ga. App. 459, 618 S.E.2d 47 (2005).
Shareholder's award of lost wages was not an open account; 12 percent interest was properly added to the award under O.C.G.A. § 7-4-12 as it existed at the time of the judgment. Gallagher v. McKinnon, 273 Ga. App. 727, 615 S.E.2d 746 (2005).
In a suit in which an insured contended that an insurer acted with negligence or in bad faith in failing to honor an accident victim's time-sensitive demand for settlement in the amount of the policy limits, the insured was not precluded from seeking post-judgment interest, at a rate of 12% per annum, under O.C.G.A. § 7-4-12 upon a judgment that was rendered in 2004 in favor of the victim and against the insured simply because the insurer later tendered the policy limits. Hulsey v. Travelers Indem. Co. of Am., 460 F. Supp. 2d 1332 (N.D. Ga. 2006).
Trial court erred when the court imposed a fixed rate of interest on a judgment obtained by a class of retirees in their action against the Teachers Retirement System of Georgia, arising from their claims that they were not paid the appropriate amounts for their retirement benefits, as there was no pre- or post-judgment interest rate established by the written contract between the parties that governed those payments, such that the statutory rates of seven percent and prime plus three percent should have been applied pursuant to O.C.G.A. §§ 7-4-2(a)(1)(A) and7-4-12(a); another interest rate that was set by the System in a regulation was not applicable to the instant matter. Teachers Ret. Sys. v. Plymel, 296 Ga. App. 839, 676 S.E.2d 234 (2009).
Husband's concern about the interest rate of 11.25 percent imposed on an award of attorneys fees was justified under circumstances in which the husband asserted that the date of the judgment was October 1, 2007, and the applicable prime rate was seven and three quarters percent, while the wife argued that the applicable prime rate was eight and one quarter percent, the rate on July 20, 2007, the day the trial court orally pronounced the court's judgment; however, an oral pronouncement was not a judgment. It had to have been reduced to writing and entered as a judgment to have been effective. Mongerson v. Mongerson, 285 Ga. 554, 678 S.E.2d 891 (2009), overruled on other grounds, 288 Ga. 670, 706 S.E.2d 456 (2011).
Judgment exempted from statutory rate.
- Although the record contained no written contract between the parties, when the plaintiff's complaint alleged that the defendants contracted, in addition to paying for the plaintiff's services, to pay the plaintiff 1.5 percent per month interest, this contractual provision constituted an obligation under O.C.G.A. § 7-4-12, which exempted the judgment from the post-judgment rate of 12 percent. Sellers v. Nodvin, 207 Ga. App. 742, 429 S.E.2d 138 (1993).
Timing
Money judgments bear interest from their dates of entry both at law and in equity. Guernsey v. Phinizy, 113 Ga. 898, 39 S.E. 402, 84 Am. St. R. 270 (1901).
Interest accrues until paid.
- Under O.C.G.A. § 7-4-12, interest on a judgment continues to accrue at the rate of 12 percent per annum until paid; such post-judgment interest is a damage that the plaintiffs recover against the defendants, and is included in calculating the recovery against it for purposes of O.C.G.A. § 51-12-14, because post-judgment interest at 12 percent is intended to deter post-judgment delay, motions, and appeals and to bring finality to judgments or the defendant pays the price of protracted post-judgment litigation. Sec. Life Ins. Co. v. St. Paul Marine & Fire Ins. Co., 263 Ga. App. 525, 588 S.E.2d 319 (2003).
Deposits in court not subject to prejudgment and postjudgment interest.
- In a contract action, a party was not entitled to prejudgment and postjudgment interest when deposits were made pursuant to the requirements of O.C.G.A. § 9-11-67. Sacha v. Coffee Butler Serv., Inc., 215 Ga. App. 280, 450 S.E.2d 704 (1994).
Judgment in action of trover bears interest from time of entry.
- Judgment in action of trover for gross amount made up of value of mules and their hire bears interest from time of entry. O'Neil Mfg. Co. v. Woodley, 118 Ga. 114, 44 S.E. 980 (1903).
Postjudgment interest ran from date of original judgment entered on the jury's verdict, not from the date on which the judgment of the appellate court reversing the grant of the motion for JNOV was made the judgment of trial court. Wilensky v. Blalock, 205 Ga. App. 845, 424 S.E.2d 26 (1992).
When two appeals were taken from an original judgment on a note, and the trial court's judgment in favor of the creditor as to liability on the note was affirmed in both appeals, postjudgment interest ran, not from the date the trial court adopted the appellate judgment, but from the date the original judgment was entered in the trial court. Groover v. Commercial Bancorp, 220 Ga. App. 13, 467 S.E.2d 355 (1996).
Application
Interest on confirmed arbitration award.
- Trial court properly awarded postjudgment interest after the court confirmed an arbitration award; once confirmed, the arbitration was treated like all other judgments, and under O.C.G.A. § 7-4-12(a), all judgments bore annual interest on the principal amount recovered. Airtab, Inc. v. Limbach Co., LLC, 295 Ga. App. 720, 673 S.E.2d 69 (2009).
Accrual of interest when more than one judgment entered.
- When a first judgment lacks an evidentiary or legal basis, postjudgment interest accrues from the date of the second judgment; when the original judgment was basically sound but was modified on remand, postjudgment interest accrues from the date of the first judgment. CRS Sirrine, Inc. v. Dravo Corp., 219 Ga. App. 301, 464 S.E.2d 897 (1995).
After the trial court's finding of liability was confirmed on appeal and the case was simply remanded for clarification of the damage award, and when the second judgment awarded exactly the same amount of damages, postjudgment interest would run from the date of the original judgment. CRS Sirrine, Inc. v. Dravo Corp., 219 Ga. App. 301, 464 S.E.2d 897 (1995).
Deposit into registry of court for less than amount of entire judgment.
- Defendant city's deposit into the registry of the court did not constitute a valid tender of the entire judgment in a condemnation action, notwithstanding that the deposit was in an amount greater than the judgment rendered for the plaintiff, since the deposit was for the payment of judgments rendered to two plaintiffs and was in an amount less than their combined judgments and, therefore, the plaintiff was entitled to postjudgment interest. Chouinard v. City of East Point, 248 Ga. App. 768, 546 S.E.2d 827 (2001).
Post-judgment interest under O.C.G.A. § 13-6-11. - Trial court properly excluded an award of pre-judgment interest in calculating the amount of post-judgment interest and properly applied post-judgment interest to the award of attorney fees under O.C.G.A. § 13-6-11. Davis v. Whitford Props., 282 Ga. App. 143, 637 S.E.2d 849 (2006).
As to postjudgment interest in condemnation cases, O.C.G.A. § 7-4-12 supersedes O.C.G.A. § 32-3-19 as § 7-4-12 is the more recent of the two. DOT v. Vest, 160 Ga. App. 368, 287 S.E.2d 85 (1981).
Section does not apply to awards of special masters.
- O.C.G.A. § 7-4-12 applies only to judgments; any interest accruing under O.C.G.A. § 22-2-113 for that period of time following an award of the special master until the jury verdict and entry of final judgment is to be at the legal interest rate established by O.C.G.A. § 7-4-2, such rate being seven percent per annum. City of Atlanta v. Wright, 159 Ga. App. 809, 285 S.E.2d 250 (1981).
Favorable judgment appellant entitled to interest during pendency of appeal.
- One obtaining money judgment in lower court, who unsuccessfully appeals one's favorable judgment, is entitled to interest on one's judgment during the pendency of the appeal. Henley v. Mabry, 125 Ga. App. 293, 187 S.E.2d 309 (1972).
Interest on a favorable judgment is not abated by appealing that judgment. Heath v. L.E. Schwartz & Sons, 203 Ga. App. 91, 416 S.E.2d 113 (1992).
Filing of garnishment proceedings by the judgment creditor during the pendency of an appeal by the debtor did not toll the accrual of post-judgment interest, even if the garnishee paid the funds into the court. Great S. Midway, Inc. v. Hughes, 223 Ga. App. 643, 478 S.E.2d 400 (1996).
When a claim for principal judgment debt interest arises in a later-filed garnishment action, it is more akin to a request for prejudgment interest because the judgment creditor seeks to recover interest running from before the trial court enters judgment in the garnishment action and, in fact, from before the garnishment action was even commenced. St. Paul Reinsurance Co. v. Ross, 276 Ga. App. 135, 622 S.E.2d 374 (2005).
Administrator acting as mere stakeholder is not liable for interest on judgment rendered against the administrator when the administrator did not make an appeal and was at all times ready to make payment. Truett v. Williams, 101 Ga. 311, 28 S.E. 851 (1897).
Operation of section in condemnation proceedings under "three assessor" law contained in Title 22. - When, in condemnation proceeding under the "three assessor" law as contained in Title 22, the amount of the final judgment is less than the award made by the assessors, condemnee is not liable for a refund of interest on the difference in the amount of the award and judgment except from the date of judgment. City of Atlanta v. Lunsford, 105 Ga. App. 247, 124 S.E.2d 493 (1962).
Verdict need not provide for future interest.
- As all judgments bear interest from the date of rendition under former Civil Code, § 3432 (see now O.C.G.A. § 7-4-12), it is immaterial that the verdict does not provide for future interest and judgment, insofar as the verdict provides for future interest, is lawful, and is not invalid upon ground that the judgment does not follow the verdict. Lang v. South Ga. Inv. Co., 38 Ga. App. 430, 144 S.E. 149 (1928).
Judgment for principal and interest due bears interest only upon principal.
- Judgment may be legally entered for principal sum and interest due on claim sued on to the date of judgment. However, such judgment only bears interest from its date on principal sum. The interest found to be due at date of judgment does not bear interest. Southern Loan Co. v. McDaniel, 50 Ga. App. 285, 177 S.E. 834 (1934); West v. Jamison, 182 Ga. App. 565, 356 S.E.2d 659 (1987).
Objection to judgment bearing interest on principal and interest well taken.
- Objection that when verdict included both principal and interest in one gross sum, and that unless corrected the judgment entered thereon would bear interest against the defendant upon both principal and interest of the balance of the original debt, was well taken under former Code 1882, § 2054. Hubbard v. McRae, 95 Ga. 705, 22 S.E. 714 (1895); Linder v. Renfroe, 1 Ga. App. 58, 57 S.E. 975 (1907).
When verdict does not separate principal and interest, new trial granted.
- When verdict in favor of the plaintiff manifestly includes both principal and interest, and does not specifically separate the amount of each, a new trial will be granted. Bentley v. Phillips, 171 Ga. 866, 156 S.E. 898 (1930).
Interest on vacated partial summary judgment not awardable.
- Although a partial summary judgment is a judgment for purposes of O.C.G.A. § 7-4-12, when the court vacated such a judgment, no post-judgment interest could be awarded on that judgment. Crolley v. Haygood Contracting, Inc., 207 Ga. App. 434, 429 S.E.2d 93 (1993).
Bankruptcy "cramdown" provisions.- Motor vehicle finance company was entitled to receive interest from bankruptcy debtor under the Chapter 13 cramdown provisions at the state legal rate of 12%, and not at the installment contract rate of 14%, since there was no evidence other than the contract of a prevailing rate other than 12%, and since there was no evidence that the debtors acted in bad faith in proposing the Chapter 13 plan. In re Mitchell, 191 Bankr. 957 (Bankr. M.D. Ga. 1995).
Effect of party's dilatory practices.
- Plaintiff, a long-term disability benefits claimant, sought pre-judgment interest under O.C.G.A. § 7-4-12 on a benefits award against the defendant plan administrator; however, denial of interest was not an abuse of discretion since the amount of interest sought was greater than the claimant's award of benefits and claimant bore some fault for the extended period of time required to litigate the case due to the claimant's several amended complaints, requests to extend discovery times and other deadlines, and motion to disqualify the judge. Byars v. Coca-Cola Co., 517 F.3d 1256 (11th Cir. 2008).
Interest award reversed.
- Award of interest for a client against an attorney from the date that the client satisfied an underlying judgment against the client, the client's son, and the attorney had no legal basis and was reversed; it had been established that the client, the client's son, and the attorney were joint tortfeasors and while O.C.G.A. § 10-7-51 authorized the award of interest running from the date of a co-surety's payment of a joint obligation, it applied to contribution actions arising from joint instruments executed by the sureties, not to joint tortfeasors. The issue was not controlled by O.C.G.A. § 9-13-78 as the statute provided a method of enforcing contribution from a joint defendant and it did not purport to control an award of interest; O.C.G.A. § 7-4-12 provided that all money judgments bore post-judgment interest from the date of entry. Gerschick v. Pounds, 281 Ga. App. 531, 636 S.E.2d 663 (2006), cert. denied, No. S07C0191, 2007 Ga. LEXIS 95 (Ga. 2007).
OPINIONS OF THE ATTORNEY GENERAL
Distinction between condemnation cases based on date filed.
- Condemnation cases filed before July 1, 1980, bear interest at seven percent on amount recovered from date of taking. Cases filed on and after July 1, 1980, bear interest at seven percent from date of taking to date of final judgment and at 12 percent from date of final judgment. 1980 Op. Att'y Gen. No. 80-100.
RESEARCH REFERENCES
Am. Jur. 2d.
- 44B Am. Jur. 2d, Interest and Usury, § 38.
C.J.S.- 47 C.J.S., Interest and Usury; Consumer Credit, § 60 et seq.
ALR.
- Statute of limitation applicable to interest on judgment, 120 A.L.R. 719.
Time when interest ceases to run upon obligation secured by lien transferred to proceeds of sale of the property free from liens in receivership, bankruptcy, or other proceedings, 134 A.L.R. 846.
Date of verdict or date of entry of judgment thereon as beginning of interest period on judgment, 1 A.L.R.2d 479.
Recovery of interest on claim against a governmental unit in absence of provision in contract or express statutory provision, 24 A.L.R.2d 928.
Right to interest on unpaid alimony, 33 A.L.R.2d 1455.
Interest on decree or judgment of Probate Court allowing a claim against estate or making an allowance for services, 54 A.L.R.2d 814.
Interest upon arrearages or unpaid accumulations of annuities, 66 A.L.R.2d 857.
Date from which interest on judgment starts running, as affected by modification of amount of judgment on appeal, 4 A.L.R.3d 1221.
Right to interest, pending appeal, of judgment creditor appealing unsuccessfully on ground of inadequacy, 15 A.L.R.3d 411; 11 A.L.R.4th 1099.
Running of interest on judgment where both parties appeal, 11 A.L.R.4th 1099.
Retrospective application and effect of state statute or rule allowing interest or changing rate of interest on judgments or verdicts, 41 A.L.R.4th 694.
Divorce and separation: award of interest on deferred installment payments of marital asset distribution, 10 A.L.R.5th 191.
Date on which postjudgment interest, under 28 USCS sec. 1961 (a), begins to accrue on federal court's award of attorneys' fees, 111 A.L.R. Fed. 615.
Determination of appropriate Chapter 11 "cramdown" rate of interest, 17 A.L.R. Fed. 3d 8.