Dual-Temp of Ill., Inc. v. Hench Consulting, Inc.

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Plaintiff won a judgment in a breach of contract claim. The court’s memorandum opinion and order, held the defendants liable for “$113,500 plus interest accruing and attorneys’ fees.” When entering the judgment on the docket, the court checked the box indicating that no prejudgment interest would be awarded. Plaintiff moved to “quantify interest based on the memorandum opinion and order.” The defendants filed appeals. Because the district court had not quantified prejudgment interest, the Seventh Circuit ordered the parties to file memoranda explaining why the appeals should not be dismissed for lack of appellate jurisdiction. Meanwhile, the district court addressed the motion to quantify, which it construed as a motion to correct the judgment. Explaining that it had checked the wrong box on the judgment, the court directed plaintiff to move the Seventh Circuit for leave to correct the clerical mistake. Plaintiff filed the motion. The Seventh Circuit held that there is no final judgment to appeal. The award of prejudgment interest is part of a plaintiff’s damages and the district court must quantify damages before a judgment can be final. Even if the clerical mistake were corrected, the judgment would not quantify prejudgment interest and the district court did not address how it would quantify the award. View "Dual-Temp of Ill., Inc. v. Hench Consulting, Inc." on Justia Law