Mooney v. Roller Bearing Company of America Inc
23-3683
9th Cir.Jun 5, 2025Background
- Richard Mooney, a former employee, sued Roller Bearing Company of America (RBC) alleging wrongful termination under the federal Family and Medical Leave Act (FMLA) and the Washington Family and Medical Leave Act (WFMLA).
- Mooney claimed he was terminated due to age, depression, and use of FMLA leave; RBC argued the discharge was part of a COVID-19-related reduction in force.
- Mooney initially filed the case in state court, but RBC removed it to federal court; Mooney did not object to removal.
- At trial, the jury received combined instructions on the state and federal claims and awarded Mooney $160,000 without distinguishing between the two statutory bases.
- Post-trial, the parties disputed whether prejudgment interest should be calculated using a federal (lower) or state (higher) interest rate.
- The district court exercised its discretion, applying a fluctuating federal rate, leading to this appellate challenge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal or state prejudgment interest applies | State rate should apply due to state claims | Federal rate is proper | District court has discretion; applying fed rate was proper given the facts |
| Calculation method for prejudgment interest | State's higher, fixed rate is compensatory | Fluctuating federal rate better compensates | Federal fluctuating rate is a reasonable, equitable choice |
| District court discretion in selecting a rate | Discretion constrained by dominance of state law | Full discretion, regardless | District court may weigh case specifics, compensation fairness, and equities |
| Effect of indistinguishable verdict (mixed claims) | Undifferentiated verdict favors higher rate | Combined claims justify federal rate | Discretion applies when verdict doesn't separate federal and state bases |
Key Cases Cited
- Oak Harbor Freight Lines, Inc. v. Sears Roebuck & Co., 513 F.3d 949 (9th Cir. 2008) (federal rate applies to prejudgment interest on purely federal claims)
- In re Exxon Valdez, 484 F.3d 1098 (9th Cir. 2007) (state rate applies for prejudgment interest on purely state claims)
- W. Pac. Fisheries, Inc. v. SS President Grant, 730 F.2d 1280 (9th Cir. 1984) (trial courts may adjust prejudgment interest rate based on factual equities)
- Dishman v. UNUM Life Ins. Co. of Am., 269 F.3d 974 (9th Cir. 2001) (prejudgment interest compensates, not penalizes)