Jimmy Lee Bynum, Jr. v. Bandza et al.

Summary

The United States District Court for the Central District of Illinois determines the prejudgment interest owed on a $57,500 backpay jury award to Jimmy Lee Bynum, Jr. The court rejects the defendants’ arguments to delay accrual until April 2022 or end it after a 2023 settlement conference, but concludes that interest ends when damages were meaningfully ascertained. Applying an agreed 6% rate from September 1, 2018 through May 6, 2025, the court awards $22,200.22 in prejudgment interest.

Holdings

1. Prejudgment interest generally accrues from the date of the plaintiff's termination, and alleged failure to mitigate damages does not displace that period absent a showing that the conduct was sufficiently egregious.
2. Prejudgment interest ends when the damages are ascertained in a meaningful way, which in this case was the date of the jury's precise damages award, not the date of a settlement conference or the later filing of Plaintiff's damages schedule.
3. September 2018 must be included in the prejudgment-interest calculation because Plaintiff's employment would have continued throughout that month absent his termination and the accrual period begins on the termination date.
4. The court used a 6% interest rate because the parties agreed that rate was proper and Seventh Circuit precedent requires use of the prime rate for prejudgment interest.

Questions Presented

1. Whether prejudgment interest should begin on the date of Plaintiff's termination or a later date based on alleged failure to mitigate damages.
2. Whether prejudgment interest should terminate at the October 2023 settlement conference or when the jury meaningfully ascertained the damages.
3. Whether September 2018 should be included in the prejudgment-interest calculation.
4. What interest rate and total amount of prejudgment interest should be awarded.

Disposition

other