Russ Ropken and Debi Ropken v. YJ Construction, Inc., a Wyoming corporation

Summary

The Wyoming Supreme Court affirmed an award of prejudgment interest following a jury verdict in favor of YJ Construction for unpaid construction work. The Court held that a district court may determine and award prejudgment interest even when a jury decided the underlying damages, and that the claim was liquidated and adequately noticed. The Court also declined to consider the appellants’ due process argument because it was not raised in the district court.

Holdings

1. A Wyoming district court has authority to consider and award prejudgment interest even when it was not the trier of fact.
2. YJ was entitled to prejudgment interest because its claim was liquidated and the Ropkens received notice of the amount due before interest began to accrue.
3. The court declined to consider the Ropkens' due-process claim because they did not raise it in the district court and did not show that the claim was jurisdictional or fundamental in nature.

Questions Presented

1. Whether a Wyoming district court may award prejudgment interest when a jury, rather than the court, determined the underlying damages.
2. Whether YJ's damages claim was liquidated and whether the Ropkens received sufficient notice of the amount due to support prejudgment interest.
3. Whether awarding prejudgment interest without an evidentiary hearing violated the Ropkens' due-process rights.

Disposition

affirmed