Long v. Castle Texas Production Ltd. Partnership, 426 S.W.3d 73

Castle sued the Long Trusts for breach of a joint operating agreement and related gas conversion claims; Castle prevailed on its counterclaims for joint interest billings.
An initial 2001 judgment awarded prejudgment interest without a stated calculation; appellate remand directed recalculation under the jo int operating agreement.
On remand (2005–2009), the trial court required new evidence to determine when the Long Trusts received the relevant billings; Castle waived prejudgment interest instead of supplying evidence.
The trial court entered a final judgment in 2009 awarding postjudgment interest from the 2001 judgment date; the court of appeals affirmed.
The Long Trusts challenged whether postjudgment interest should run from the original 2001 judgment date or the final 2009 judgment date after remand for new evidence.
The Court of Appeals’ remand decision did not overturn the trial court’s finding that new evidence was needed; the supreme court reversed to set accrual from the final judgment date.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Date postjudgment interest accrues when remand requires new evidence	Castle argues interest from 2001 date should apply	Long Trusts argue accrues from final remand judgment	Accrual from final judgment date when remand requires new evidence
Effect of Rule 43.3 exception on accrual	Remand allows original judgment date if appellate renders correct judgment	Remand with new evidence necessitates final judgment accrual	Rule 43.3 applies; dual judgments on remand lead to final judgment accrual
Whether the trial court erred in reopening the record	Record already supported prejudgment interest; no reopening needed	Remand required new evidence to determine prejudgment interest	Trial court did not abuse discretion in reopening; evidence needed
Impact of waiver on accrual date	Waiver of prejudgment interest should not affect accrual rule	Waiver reflects lack of record and affects accrual	Waiver does not alter accrual date; accrual is governed by final judgment date
Severance or partial judgments affect accrual	Severance could affect when interest runs on severed claims	Severance is not determinative; accrual follows final judgment rule	Severance does not mandate different accrual; final judgment date governs

Bramlett v. Kenneco Energy, Inc., 407 S.W.3d 229 (Tex. 2013) (sets framework: final judgment rule and remand for new evidence affects accrual)
American Paper Stock Co. v. Howard, 528 S.W.2d 576 (Tex. 1975) (when appellate renders correct judgment, postjudgment interest from trial court date)
D.C. Hall Transport, Inc. v. Hard, 358 S.W.2d 117 (Tex.Civ.App.-Fort Worth 1962) (remand without new evidence supports interest from original judgment)
Thornal v. Cargill, Inc., 587 S.W.2d 384 (Tex. 1975) (reformation to award interest from trial court’s erroneous judgment)
Gamma Group v. Transatlantic Reinsurance Co., 365 S.W.3d 469 (Tex.App.-Dallas 2012) (retrials and remands do not always align with accrual rules)
State Department of Highways & Pub. Transp. v. City of Timpson, 795 S.W.2d 24 (Tex.App.-Tyler 1990) (early view on original-judgment accrual for remands)
Danziger v. San Jacinto Savings Ass'n, 732 S.W.2d 300 (Tex. 1987) (severance and remand of part of claim; postjudgment interest from original judgment)
Vassallo v. Nederl-Amerik Stoomv Maats Holland, 344 S.W.2d 421 (Tex. 1961) (illustrative severance/interest principles in remand context)