Welded Construction, L.P. v. The Williams Companies, Inc., 19-50194

The case arises from an adversary proceeding in bankruptcy court regarding post-judgment interest and penalties under the Pennsylvania Contractor and Subcontractor Payment Act (CASPA).
Welded Construction, L.P. (Welded) and Transco disagreed on whether CASPA interest and penalties continue to accrue after a federal judgment is entered.
The sole dispute was over the form and effect of the final federal judgment: whether state law (CASPA) or federal law (28 U.S.C. § 1961) governs post-judgment interest and penalties.
Welded argued according to Pennsylvania state law and a state case (Zimmerman) that CASPA remedies should persist post-judgment until payment is made in full.
Transco argued for the application of the federal post-judgment interest statute, claiming state penalties terminate at judgment entry in federal courts.
The Bankruptcy Court addressed the issue for the first time at this stage, as it had not been previously briefed in the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CASPA interest/penalty accrues post-judgment in federal court	CASPA interest and penalty continue accruing until paid	Once judgment is entered, federal interest rate applies and CASPA penalties/interest end	CASPA penalties cease on judgment entry; post-judgment interest governed by 28 U.S.C. § 1961

Zimmerman v. Harrisburg Fudd I, L.P., 984 A.2d 497 (Pa. Super. Ct. 2009) (considered whether CASPA penalties accrue post-judgment; interpreted liberally for remedial purposes)
Resyn Corp. v. United States (In re Resyn Corp.), 945 F.2d 1279 (3d Cir. 1991) (held federal post-judgment interest statute applies to bankruptcy court judgments)
Sovereign Bank v. Remi Cap., Inc., 49 F.4th 360 (3d Cir. 2022) (held private contract could override the default federal post-judgment interest rate if intent is clear)