Lockley v. CSX Transportation Inc.
66 A.3d 322
| Pa. Super. Ct. | 2013Background
- CSX Transportation appeals a March 20, 2012 order awarding post-judgment interest to Lockley from the verdict date (May 5, 2008) rather than the judgment date (March 30, 2009).
- Trial on FELA/FLIA claims produced a $2,000,000 verdict with 22% comparative negligence attributed to Lockley.
- Post-trial relief was denied; the Superior Court affirmed the trial court’s decision, and the Pennsylvania Supreme Court denied allocator and relinquished jurisdiction in 2011.
- Lockley filed praecipe for post-judgment interest in January 2012; CSX moved to strike, initially grounding it in Rule 1037 but later asserted a broader challenge to the calculation.
- The trial court granted post-judgment interest from the verdict date, awarding $440,219.18; CSX timely appealed.
- Pennsylvania law (42 Pa.C.S.A. § 8101) governs post-judgment interest, and the court concluded it is procedural, not substantive, thus PA law applies despite federal substantive claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Starting date for post-judgment interest | Lockley: interest accrues from verdict date under §8101. | CSX: federal law dictates accrual date; Monessen/ Kaiser considerations apply. | Interest accrues from verdict date; PA §8101 controls. |
| Waiver/preservation of challenging post-judgment interest calculation | CSX preserved challenge by timely strike motion; not waived. | CSX waived by not appealing the verdict/damages earlier. | CSX did not waive challenge; merits addressed. |
| Characterization of post-judgment interest as procedural vs substantive | Federal substantive law governs substantive rights, but not interest accrual. | Post-judgment interest is substantive under federal law. | Post-judgment interest is procedural; PA law applies to calculation and date. |
Key Cases Cited
- Hutchison ex rel. Hutchison v. Luddy, 946 A.2d 744 (Pa.Super.2008) (challenge to separate post-judgment interest motion after multiple appeals)
- Monessen Southwestern Ry. Co. v. Morgan, 486 U.S. 330 (Supreme Court 1988) (prejudgment interest in FELA; limits on local rules)
- Kaiser Aluminum & Chem. Corp. v. Bonjorno, 494 U.S. 827 (Supreme Court 1990) (when post-judgment interest begins under 28 U.S.C. § 1961; federal court context)
- Payne v. Commonwealth, Dept. of Corrections, 871 A.2d 795 (Pa. 2005) (distinguishes substantive vs. procedural law in context of rights and enforcement)
- Nissho-Iwai Co., Ltd. v. Occidental Crude Sales, Inc., 848 F.2d 613 (5th Cir.1988) (classification of post-judgment interest as procedural; functional analysis)
- Louisville & Nashville R.R. Co. v. Stewart, 241 U.S. 261 (Supreme Court 1916) (allowing state interest rate controls in FELA actions)