In Briggs v. Pennsylvania R.R. Co., 334 U.S. 304, 68 S.Ct. 1039, 92 L.Ed. 1403 (1948), the district court entered judgment for the defendant notwithstanding the verdict after granting a motion to dismiss for lack of jurisdiction. See 334 U.S. at 305, 68 S.Ct. 1039. Without making provision for post-judgment interest, the court of appeals reversed and directed that judgment be entered on the verdict. See id. Relying on the principle that "an inferior court has no power or authority to deviate from the mandate issued by an appellate court," the Supreme Court held that the district court could not award post-judgment interest from the date of the verdict because "the trial court had no power to enter judgment for an amount different than directed." Id. at 306, 68 S.Ct. 1039.