Summary
This Seventh Circuit opinion determines whether post-judgment interest on a $140 million punitive damages award should accrue from the initial 2017 district court judgment or a later 2022 judgment. Applying 28 U.S.C. § 1961(a) and Supreme Court precedent, the court concludes that the final punitive amount was ascertainable when the first judgment was entered. The appellate court reverses the district court’s ruling and remands with instructions to calculate interest beginning on October 3, 2017.
Topics
Practice areas
Questions Presented
- Whether post‑judgment interest on the $140 million punitive award should run from the 2017 judgment or the 2022 judgment
- Whether the constitutional limit on punitive damages affects the date from which interest accrues
Holdings
- Post‑judgment interest on the $140 million punitive award runs from October 3, 2017, the date of the first judgment.
- The constitutional limit does not affect the date interest begins; the award is considered ascertainable from the first judgment.
Key quotations
“We conclude that an award of $140 million in punitive damages was “ascertainable” from the entry of the first judgment in 2017.”
“The district court’s decision is reversed, and the case is remanded with instructions to award postjudgment interest on the $140 million punitive award starting October 3, 2017.”
Factual background
A jury found that Tata Consultancy Services misappropriated Epic Systems' confidential information and awarded $240 million in compensatory damages and $700 million in punitive damages. The district court later reduced the awards, ultimately leaving a $140 million punitive award, which the parties disputed for post‑judgment interest purposes.
Procedural history
The district court entered a $940 million judgment in 2017 (compensatory $240M, punitive $700M). The court later reduced compensatory damages to $140M and punitive damages to $280M. On remand, the district court set punitive damages at $140M, the constitutional maximum, and later denied Tata’s request to further reduce punitive damages. The district court awarded post‑judgment interest on compensatory damages from 2017 but held that interest on punitive damages should run from the 2022 judgment. Epic appealed.
Remand instructions
Award post‑judgment interest on the $140 million punitive award starting October 3, 2017.