H1 LINCOLN, INC. v. SOUTH WASHINGTON STREET, LLC, & Others., SJC-13651

H1 Lincoln, Inc. sued South Washington Street, LLC and related entities for breach of contract, breach of implied covenant of good faith and fair dealing, and violation of G.L. c. 93A regarding a commercial property lease.
Plaintiff prevailed at trial and on appeal, resulting in a judgment of over $20 million.
After judgment, the defendants paid the full amount but reserved their right to appeal the case.
The Superior Court judge ordered that, upon full payment, the parties must dissolve property attachments and lis pendens; if any condition was attached to payment, it would not satisfy the judgment.
The central dispute was whether postjudgment interest should continue to accrue after the defendants fully paid the judgment but reserved their appellate rights.
The Appeals Court affirmed continued accrual of interest post-payment; the Supreme Judicial Court granted further appellate review on this limited issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does reserving appellate rights make payment conditional, so postjudgment interest continues accruing?	Full use and enjoyment of payment is not realized while appeal risks remain, so interest should accrue.	Reserving appellate rights does not make the payment conditional—payment in full ends interest accrual.	Exercise of appellate rights is not a condition; full payment stops interest accrual.
Must any property attachment/lis pendens remain after payment and appeal?	Dissolution contingent on true satisfaction of judgment, which includes ending interest accrual only when risks of appeal are gone.	Dissolution is required upon full payment, as they are only to secure the judgment, not punitive.	Dissolution is a consequence of full payment, not a condition.
What is the proper standard for reviewing whether payment satisfied the judgment and halted interest?	Judge’s decision should be affirmed for abuse of discretion.	This is a legal question requiring de novo review.	De novo review applies; payment in full satisfies the judgment as a matter of law.
Does public policy warrant continued interest accrual until all possible appeals have ended?	Continued accrual encourages full and final satisfaction, even during appeal process.	Requiring continued interest would discourage prompt payment and penalize appeals.	Legislature's intent is to encourage prompt payment; postjudgment interest halts at full payment.

Governo Law Firm LLC v. Bergeron, 487 Mass. 188 (explains standard of review on payment satisfaction and interest accrual)
Commerce Ins. Co. v. Szafarowicz, 483 Mass. 247 (addresses discretion and payment into court)
City Coal Co. of Springfield v. Noonan, 434 Mass. 709 (interest accrues until judgment fully satisfied)
Osborne v. Biotti, 404 Mass. 112 (purpose of postjudgment interest is compensatory, not punitive)
Debral Realty, Inc. v. DiChiara, 383 Mass. 559 (explains purpose of lis pendens in litigation)
Cohen v. Murphy, 368 Mass. 144 (payment of judgment may later require restitution if appeal succeeds)
Onofrio v. Department of Mental Health, 411 Mass. 657 (interest compensates for delay in payment of damages)