Parkway 1046, LLC v. U.S. Home Corporation, No. 18-1556 (4th Cir. 2020)
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U.S. Home challenges the district court's orders granting judgment, prejudgment interest, and attorneys' fees to Parkway in an action stemming from disputes over land and purchase development contracts.
The Fourth Circuit held that the plain language of the contracts supports the district court's conclusion that Parkway's lawsuit is timely. In this case, Parkway's cause of action did not accrue until 2017, and the lawsuit was filed in the same year. However, the court held that the district court erred in ordering U.S. Home to pay prejudgment interest dating from May 27, 2008 and attorneys' fees. Under Maryland law, the court explained that Parkway is entitled to prejudgment interest only from the date of the purchase in 2017. Under the contract, Parkway may not be awarded attorneys' fees. Accordingly, the court reversed and vacated in part, remanding for instructions to award prejudgment interest from April 21, 2017.
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