Kaiser Aluminum & Chemical Corp. v. Bonjorno

Background

A former small company owner (Bonjorno) sued a large aluminum maker (Kaiser), claiming Kaiser had illegally monopolized the market. After a long series of trials and appeals, a jury awarded trebled antitrust damages in December 1981, and Kaiser later paid the December 1981 award. The parties disputed when postjudgment interest should start and which version of the federal interest law (the old state-rate rule or the 1982 Treasury-bill rule) applied.

Reasoning

The Court focused on the wording of the federal postjudgment interest statute, which ties interest to the "date of the entry of the judgment." It held that interest runs from the date the court enters the judgment (here December 4, 1981), not from the date the jury returned its verdict. The Court also rejected using an earlier judgment that was later found unsupported by the evidence. Finally, because Congress set the Treasury-bill rate to take effect October 1, 1982, the Court held that the 1982 amendment does not apply to judgments entered before that effective date, so earlier state-based rates govern those pre-October 1982 judgments.

Real world impact

The ruling decides how much and when interest accrues on many federal money judgments. Plaintiffs and defendants nationwide should expect interest to be calculated from the entered judgment date, and judgments entered before October 1, 1982, keep the older state-rate method. The case was sent back to lower courts for compliance with this ruling.

Dissents or concurrances

Justice Scalia agreed but discussed broader rules about retroactivity; Justice White dissented, arguing the 1982 amendment should have applied to this pending case.