Kaiser Aluminum & Chemical Corp. v. Bonjorno
494 U.S. 827 (1990)
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Rule of Law:
Federal postjudgment interest under 28 U.S.C. § 1961 is calculated from the date a legally valid judgment is entered, and the applicable interest rate is determined by the version of the statute in effect on that specific date, not by subsequent statutory amendments.
Facts:
- Columbia Metal Culvert Co., Inc., whose sole stockholders were Bonjorno, was a fabricator of aluminum drainage pipe in New Jersey.
- Kaiser Aluminum & Chemical Corp. (Kaiser) was a competitor of Columbia Metal in the same market.
- Bonjorno alleged that Kaiser monopolized the market for aluminum drainage pipe in the Mid-Atlantic region of the United States.
- This alleged monopolistic activity by Kaiser was claimed to have caused financial harm to Bonjorno's business in violation of the Sherman Act.
Procedural Posture:
- Bonjorno sued Kaiser in the U.S. District Court for the Eastern District of Pennsylvania, alleging antitrust violations.
- After a first trial resulted in a directed verdict for Kaiser, the U.S. Court of Appeals for the Third Circuit reversed and remanded.
- A second trial resulted in a jury verdict for Bonjorno, and judgment was entered on August 22, 1979.
- The District Court granted Kaiser's motion for a new trial on damages, finding the award unsupported by evidence.
- A retrial on damages resulted in a new jury award, and a second judgment was entered for Bonjorno on December 4, 1981.
- The District Court then granted Kaiser's motion for judgment notwithstanding the verdict (JNOV), partially reducing the damages.
- Bonjorno, as appellant, appealed the JNOV to the Third Circuit, which reversed the District Court and reinstated the full December 4, 1981 judgment.
- After Kaiser's petition for certiorari on the merits was denied, a dispute arose over postjudgment interest.
- The District Court ruled that interest ran from the verdict date (Dec 2, 1981) and applied the interest rate from the old version of § 1961.
- Both parties appealed to the Third Circuit. The appellate court affirmed the start date but reversed on the rate, holding that the amended version of § 1961 should apply retroactively.
- The U.S. Supreme Court granted certiorari to resolve the questions surrounding the calculation of postjudgment interest.
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Issue:
Under the federal postjudgment interest statute, 28 U.S.C. § 1961, does interest begin to accrue from the date of the entry of a legally sufficient judgment, and is the interest rate governed by the version of the statute in effect on that date, even if the statute is amended during subsequent appeals?
Opinions:
Majority - Justice O'Connor
Yes. Postjudgment interest is calculated from the date of the entry of a legally valid judgment, and the interest rate is fixed by the version of the statute in effect on that date. The plain language of § 1961 explicitly states that interest runs from the 'date of the entry of judgment,' not the date of a jury verdict. Furthermore, interest cannot accrue from an initial judgment that was later found to be unsupported by the evidence, as damages in such a case have not been meaningfully 'ascertained.' The language of both the original and amended versions of the statute ties the interest calculation, including the rate, directly to the judgment date. This demonstrates a clear congressional intent for the statute to apply prospectively, meaning the version of the law in effect at the time of the valid 1981 judgment is the one that controls. Because this intent is clear from the statute's text, the Court does not need to resolve the tension between its precedents in Bradley and Georgetown regarding statutory retroactivity.
Concurring - Justice Scalia
Yes. The Court correctly determines that the statute's language indicates it should be applied prospectively. However, the Court should have seized this opportunity to resolve the 'irreconcilable contradiction' between the presumption of retroactivity for pending cases established in Bradley v. Richmond School Bd. and the long-standing, traditional presumption that statutes apply prospectively unless Congress explicitly states otherwise. The Bradley rule was a mistaken departure from centuries of precedent. The correct and clear rule of construction, which should be reaffirmed, is that nonpenal legislation operates prospectively only, absent specific indication to the contrary.
Analysis:
This decision provides crucial clarity on the mechanics of 28 U.S.C. § 1961, establishing bright-line rules for calculating federal postjudgment interest. It confirms that interest starts from a legally sound judgment entry date, not an earlier verdict or an invalidated judgment, ensuring interest only accrues once damages are properly ascertained. Most significantly, by grounding its holding in the statute's plain language to find clear congressional intent for prospective application, the Court skillfully avoided the contentious judicial debate over retroactivity under its conflicting precedents, Bradley and Georgetown. This reinforces a key principle of statutory interpretation: statutory language that ties a calculation to a fixed past date serves as strong evidence against the retroactive application of any subsequent amendments.
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