John Mazor et al. v. Elizabeth Farrell

Summary

The District of Columbia Court of Appeals affirmed the denial of prejudgment interest on the Mazor brothers’ unjust-enrichment award against Elizabeth Farrell. The court held that the claim did not involve a liquidated debt under D.C. Code § 15-108 because liability and the amount owed depended on equitable circumstances, the recipient’s innocent status, and disputed tracing and damages calculations. The court did not address prejudgment interest under the common law or D.C. Code § 15-109.

Holdings

1. The claim was not an action to recover a liquidated debt because the existence and amount of Farrell's liability depended on equitable circumstances, the scope of an innocent recipient's liability, and damages amounts that fluctuated during litigation. Prejudgment interest was therefore unavailable under § 15-108.

Questions Presented

1. Whether an unjust-enrichment claim involving an innocent recipient of misappropriated funds is an action to recover a liquidated debt eligible for mandatory prejudgment interest under D.C. Code § 15-108.

Disposition

affirmed