White v. Wycoff, No. 16-1319 (10th Cir. 2017)Annotate this Case
Philip White obtained a judgment for $100,000 in compensatory damages and moved for an award of prejudgment interest. The district court denied the motion, viewing the bulk of the award as compensation for noneconomic damages. White argued on appeal to the Tenth Circuit that the Court should: (1) overrule earlier opinions and find that prejudgment interest was always available for compensatory awards under 42 U.S.C. 1983; or (2) conclude that the district court abused its discretion in disallowing prejudgment interest. The Court rejected both of White's arguments, finding it could not overrule published opinions by other Tenth Circuit panels. Applying an abuse-of-discretion standard, the Tenth Circuit concluded: (1) the district court did not abuse its discretion in denying prejudgment interest on the award of noneconomic compensatory damages; and (2) the district court could reasonably decline to speculate on the amount the jury had regarded as economic damages.