Sutter Health v. Eden Township Healthcare District
Annotate this CaseEden Township Healthcare District, established under the Local Health Care District Law (Health & Saf. Code 32000), was subject to a money judgment of $17 million, plus $2.5 million in prejudgment interest, attorney fees, and costs. More than a year after entry of the judgment, the District sought an order permitting it to pay the judgment in 10 annual installments under Government Code 970.6 and declaring that the post-judgment interest rate will be the same as the interest rate on “one-year United States Treasury bills” in each year. (section 984 (e)(2).) In support of its claim of hardship, as required by the statute, the motion demonstrated that the District lacked sufficient funds to pay the judgment, was unable to borrow additional money against its already encumbered assets, and might be forced into bankruptcy if required to sell assets to raise the funds necessary for a lump sum payment. The trial court granted the motion. The court of appeal affirmed the grant of installment payment relief, concluding that the District’s financial straits readily support a finding of “unreasonable hardship.” While the post-judgment interest rate established by section 984 is appropriate prospectively, there is no statutory basis for reducing the interest accrued prior to the trial court’s ruling under section 970.6.
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