The following excerpt is from Rhodes v. Gary Davis, Alarm Specialists, Inc., No. 12-4347-cv (2nd Cir. 2015):
Because the "awarding of prejudgment interest is considered a question of substantive law," Schwimmer v. Allstate Ins. Co., 176 F.3d 648, 650 (2d Cir. 1999), "federal law does not apply to the calculation of prejudgment interest on supplemental state law claims" where, as here, a plaintiff does not prevail on any of his federal claims.
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