When a judgment is modified upon appeal or reversed on appeal, does the new award bear interest from the date of the original judgment?

MultiRegion, United States of America

The following excerpt is from In re Invensure Ins. Brokers, Inc., Case No. 8:19-bk-11889-SC (Bankr. C.D. Cal. 2020):

"When a judgment is modified upon appeal, whether upward or downward, the new sum draws interest from the date of the entry of the original order, not from the date of the new judgment. On the other hand, when a judgment is reversed on appeal the new award subsequently entered by the trial court can bear interest only from the date of entry of such new judgment. Whether an order by an appellate court is a modification or a reversal depends on the substance and effect of that order." Chodos v. Borman, 239 Cal. App. 4th 707, 712-13, 190 Cal. Rptr. 3d 889, 893-94 (2015) (citing Snapp v. State Farm Fire & Cas. Co., 60 Cal. 2d 816, 821, 36 Cal. Rptr. 612, 615 (1964)) (emphasis added).

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