Summary
The Ninth Circuit affirmed the district court’s use of a fluctuating federal rate to calculate prejudgment interest on a damages award based on indistinguishable federal and state family-leave claims. The court held that, when a judgment rests equally on federal and state claims without allocation between them, the district court has discretion to select the appropriate prejudgment interest rate.
Topics
Practice areas
Questions Presented
- When a judgment rests equally on undifferentiated federal and state claims, does the district court have discretion to select the applicable prejudgment-interest rate?
- Did the district court abuse its discretion by applying a fluctuating federal prejudgment-interest rate rather than the higher Washington rate?
Holdings
- When a judgment is based equally on federal and state claims without any distinction between them, the district court has discretion to select a proper prejudgment-interest rate.
- The district court did not err in applying a fluctuating federal prejudgment-interest rate because it properly exercised its discretion and found that rate to be the most accurate means of compensating Mooney for the lost use of his wages.
Key quotations
“We hold that when, as here, the judgment is based equally on federal and state claims, the district court has discretion to decide which rate applies.” (at 3)
“We therefore hold that when a judgment is based equally on both state and federal claims, the district court has discretion to select a proper prejudgment interest rate.” (at 6)
“Prejudgment interest is designed to provide fair compensation to a prevailing party.” (at 7)
Factual background
Richard Mooney alleged that his former employer terminated him because of his age, depression, and decision to take leave under the federal Family and Medical Leave Act. Roller Bearing Company contended that the termination resulted from a COVID-19-pandemic-related reduction in force. The jury found liability on Mooney's FMLA and Washington Family and Medical Leave Act claims, awarded him $160,000, and returned a verdict that did not distinguish between the federal and state claims.
Procedural history
Mooney filed suit in King County Superior Court on June 3, 2020. Roller Bearing Company removed the case to the United States District Court for the Western District of Washington on federal-question and diversity grounds on July 1, 2022. Following trial, the jury returned an undifferentiated verdict on Mooney's FMLA and WFMLA claims. The district court selected a fluctuating federal prejudgment-interest rate, and the Ninth Circuit affirmed that ruling while noting that the remaining appellate issues were addressed in a concurrently filed memorandum disposition.