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Hadley v. Maxwell

Washington Court of Appeals

84 P.3d 286 (2004)

Facts

Harry and Jewell Hadley (plaintiffs) were injured in a car accident caused by Helen and John Doe Maxwell (defendant). A jury found the Maxwells 100 percent at fault and awarded the Hadleys $136,000 in damages. The trial court entered a judgment in the Hadleys’ favor for $125,000 plus yearly interest at 12 percent beginning on June 8, 1998, the date of the judgment. The Maxwells appealed liability but not damages. The Washington Supreme Court reversed the case on a procedural issue and remanded for a retrial solely on the issue of liability. The Washington Supreme Court noted that the Maxwells had not petitioned for a review of the damages award, noted that the issue of damages had been fully and vigorously litigated at trial, and thus did not require damages to be relitigated on remand. The retrial was held in 2003, and the Maxwells were again found 100 percent at fault for the car accident. The trial court awarded postjudgment interest from the date of the 2003 judgment. The Hadleys appealed, arguing that the trial court should have awarded interest from the date of the 1998 judgment.

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Holding and Reasoning (Brown, C.J.)

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