Medical Mutual Liability Insurance Society of Md. v. Davis

In Medical Mutual Liability Insurance Society of Md. v. Davis, 365 Md. 477, 781 A.2d 781 (2001), the Court of Appeals was asked to decide when postjudgment interest begins to accrue on a money judgment based on a jury verdict when the judgment is subsequently reduced via a remittitur. In Davis, the plaintiffs brought a medical malpractice wrongful death and survival actions against a doctor based on alleged negligence in connection with the birth of their son. The jury returned a verdict in favor of the plaintiffs, and six days later, a judgment was entered in the circuit court's docket. Two days after the judgment was entered, the doctor filed a motion for a new trial or, in the alternative, for a remittitur. After a hearing, the circuit court reduced the amount of the judgment subject to the plaintiff's acceptance of the remittitur, and the clerk entered the new judgment on the docket. The plaintiffs accepted the remittitur and the doctor's insurer paid the judgment with postjudgment interest from the date of their acceptance of the remittitur. The plaintiffs subsequently sought postjudgment interest from the date of the original jury verdict. The Court of Appeals held that, under the circumstances presented in Davis, postjudgment interest began to accrue on the date of the original judgment, even though the judgment later was reduced by remittitur. The Court noted that previous postjudgment interest cases stood "for the principle that postjudgment motions or appeals which may cause a money judgment for a plaintiff to lose some aspects of its finality, ordinarily do not have the effect of postponing the accrual of postjudgment interest from the date that the original money judgment was entered." Davis, supra, 365 Md. at 486.