Mich. Comp. Laws § 600.6013

Section 600.6013 requires statutory interest on a wrongful-death money judgment from the date the complaint is filed until the judgment is paid.

Vannoy v. City of Warren · filed 1970-10-29

Combining the principles of both the statute and Currie, we hold the following. In a wrongful death action, where a claim accrues as of a date certain, the jury is to be instructed to include as part of its award of damages interest from the date of injury to the date the complaint was filed. When the verdict is returned the defendant shall immediately be liable for statutory interest from the date of the complaint to the date the judgment is paid computed in accordance with MCLA § 600.6013 (Stat Ann 1970 Cum Supp § 27A.6013).

Section 600.6013 requires interest on a civil money judgment to be calculated from the date the complaint was filed, and it applies to pending actions.

Estate of Clark · filed 1971-05-18

"Interest shall be allowed on any money judgment recovered in a civil action, such interest to be calculated from the date of filing the complaint at the rate of 5% per year * * *."

Section 600.6013 allows interest on a money judgment recovered in a civil action, but a workers’ compensation carrier cannot recover interest when the judgment was entered in favor of the employee.

Banoski v. Moto-Crane Service, Inc. · filed 1971-08-24

In view of the fact that the aforementioned statute is remedial in nature and is in derogation of the common law, it must be strictly construed. Motyka v. Detroit, G. H. & M. R. Co. (1932), 260 Mich 396; Swift v. Dodson (1967), 6 Mich App 480.

Section 600.6013 is remedial or procedural, applies retrospectively, and requires interest to be calculated from the date the complaint was filed.

Cosby v. Pool · filed 1971-10-26

The amendment to the statute in contention was remedial or procedural. It in no way affects the substantive interests of the two parties. Therefore, the amendment has the effect of becoming a part of the contract and replaces the clause as written. Therefore, the interest must be calculated from the date of filing the complaint.

Section 600.6013 makes interest on a civil money judgment mandatory, calculated from the complaint filing date at the statutory rate, unlike discretionary prejudgment interest.

Militzer v. Kal-Die Casting Corp. · filed 1972-06-26

MCLA 600.6013; MSA 27A.6013 provides in part: ... "Interest shall be allowed on any money judgment recovered in a civil action, such interest to be calculated from the date of filing the complaint at the rate of 5% per year * * * .” ... Defendant fails to distinguish between judgment interest and prejudgment interest. The former is statutory and mandatory, the latter an element of damages and discretionary. ... In any event Cyranoski does not support the proposition that statutory judgment interest is a discretionary matter for the trial court. Indeed such a rule does not exist even at common law since at common law judgments did not carry interest. ... The purpose of the judgment interest statute is to compensate for loss of use of funds. ... This purpose would be thwarted if we permitted the trial court to derogate from the plain statutory mandate that interest "shall be allowed” on a money judgment.

Section 600.6013 requires interest on a civil-action money judgment from the date the complaint was filed.

Michigan Mutual Liability Co. v. Staal Buick, Inc. · filed 1972-06-28

MCLA 600.6013; MSA 27A.6013 provides that interest shall be allowed on any money judgment recovered in a civil action from the date the complaint was filed. At the same time, GCR, 1963, 118.4 provides that any amendment in pleadings relates back to the date of the original pleading whenever the claim "asserted in the amended pleading arose out of the conduct, transaction, or occurrence set forth” in the original pleading. It is clear from the statute and the court rule that the judge was correct in taxing interest as of July 18, 1966, the date the original complaint was filed.

Section 600.6013 does not control interest on a Court of Claims judgment; interest is awarded from the date of judgment under § 600.6455.

Williams v. Department of State Highways · filed 1972-12-06

The trial judge modified the judgment entered by inclusion of interest from the date the complaint was filed pursuant to MCLA 600.6013; MSA 27A.6013. Defendant contends that interest upon judgment granted by the Court of Claims may be entered only from the date of judgment. MCLA 600.6455; MSA 27A.6455. Plaintiffs concede that defendant correctly states the law, and we agree. We, therefore, enter an award of interest from the date of judgment pursuant to GCR 1963, 820.1.

Section 600.6013 makes interest on a money judgment run from the filing of the original complaint when a third-party complaint is ancillary to the overall action.

Grand Trunk Wr Co. v. Pre-Fab Transit Company, Inc. · filed 1973-03-29

We also rule that the interest statute, MCLA 600.6013; MSA 27A.6013, "interest to be calculated from the date of filing the complaint” implies that only that complaint central to the overall action is relevant for purposes of determining interest. Since a third-party complaint for contribution is not by any means central to the action, but is ancillary or auxiliary thereto, the interest statute is held to contemplate that a third-party defendant’s liability for interest runs from the date of filing of the original complaint.

Section 600.6013 generally awards interest from the date a complaint is filed, but in an indemnity action the indemnitor's liability may accrue interest from the date of judgment against the indemnitee when the underlying judgment already includes statutory interest.

McLouth Steel Corp. v. A. E. Anderson Construction Corp. · filed 1973-07-24

Although MCLA 600.6013; MSA 27A.6013, indicates interest on money judgments is to be awarded from the date of filing the complaint, we hold the modification ordered by the trial judge which would allow interest to accrue from the date of judgment against McLouth was proper. ... The amount for which the indemnitor is liable is necessarily determined by the judgment sustained by the indemnitee, which amount would then include interest payable to the original plaintiff from the date of the filing of his complaint, pursuant to MCLA 600.6013, supra.

Section 600.6013 mandates interest on a money judgment from the date the complaint was filed, including when the complaint preceded the amendment but judgment followed it.

Alpine Construction Co. v. Gilliland · filed 1973-11-28

It was not until February 1969 that the Supreme Court held that this Court was in error in applying the previous version of MCLA 600.6013, supra, to cases in which the complaint was made prior to the 1965 amendment but judgment was entered subsequent to amendment. Even though the trial court cannot be faulted for his reliance upon this Court’s holdings, since interest pursuant to MCLA 600.6013, supra, is mandatory, entry of the original order of judgment with the restriction that the interest run only from the date of judgment rather than the date of the filing of the complaint amounted to an error of law.

Section 600.6013 requires statutory judgment interest to run from the filing of the complaint.

Bruno v. Detroit Institute of Technology · filed 1974-03-04

Since the interest on the judgment statute, MCLA 600.6013; MSA 27A.6013, provides that the statutorily mandated interest on the judgment shall run from the filing of the complaint, if the damages for the years subsequent to the filing of the complaint were not reduced to their worth at that date, plaintiff, by the operation of the statute, would be given interest on monies from a time prior to the time they were owed to him. By reducing the worth of the damages to the date of the complaint and then adding the statutorily mandated interest from that date, plaintiff is made whole, and any duplicity of compensation by defendant is avoided.

Section 600.6013 requires statutory interest on a money judgment to be calculated from the date the complaint is filed, without relation back to an earlier defective complaint.

Ball v. EX-CELL-O CORPORATION · filed 1974-04-26

"Interest shall be allowed on any money judgment recovered in a civil action, such interest to be calculated from the date of filing the complaint at the rate of 5% per year.” (Emphasis supplied.) ... In this case, the complaint was filed December 27, 1962, and the language of the statute mandates that interest be calculated from that date. ... Therefore, we hold that for the purposes of statutory judgment interest plaintiff’s complaint does not relate back to a prior defective complaint.

Section 600.6013 requires interest on a civil money judgment to be calculated from the date the complaint was filed, and the same rule applies to a counter-complaint.

Goodwin, Inc. v. ORSON E. COE PONTIAC, INC. · filed 1975-07-03

"Interest shall be allowed on any money judgment recovered in a civil action, such interest to be calculated from the date of filing the complaint at the rate of 5% per year unless the judgment is rendered on a written instrument having a higher rate of interest in. which case interest shall be computed at the rate specified in the instrument if such rate was legal at the time the instrument was executed." ... We are not at liberty to determine, nor logically could we find, that a different standard than that found in the statute is to be applied to a counter-complaint. Thus, interest after damages are awarded should run from the date of the filing of the counter-complaint.

Section 600.6013 sets the judgment-interest rate and requires interest to accrue from the date the complaint is filed.

Stone v. Fawcett · filed 1975-08-18

The rate of interest, 6% per year, established by MCLA 600.6013; MSA 27A.6013, is conceded by DAIIE to be the appropriate rate of interest and applicable to the entire judgment. ... Plaintiff contends that since the interest accruing after judgment is calculated from the date of filing of the complaint according to statute, MCLA 600.6013; MSA 27A.6013, DAIIE is liable from that date, particularly since no interest is assessed or due until the judgment is rendered. ... Hence, this Court is bound to hold the garnishee defendant liable for interest from the date of the filing of the complaint.

Section 600.6013 requires interest on the class claims to be calculated from July 21, 1965, the effective date of 1965 PA 240.

Northview Construction Co. v. City of St. Clair Shores · filed 1975-12-18

We suggest that costs be taxed against the city and the city create a fund that is equal to the damages found to be due to those class members filing valid claims within the time limits established by the circuit court plus interest from July 21, 1965, the effective date of 1965 PA 240; MCLA 600.6013; MSA 27A.6013.

Section 600.6013 allows interest from the date the complaint was filed on money recovered by final judgment, but not on amounts paid in settlement without a judgment.

Awedian v. Theodore Efron Manufacturing Co. · filed 1976-01-06

The Michigan Mutual panel’s rejection of this claim was premised on MCLA 600.6013; MSA 27A.6013, which provides that interest on any money judgment shall be allowed from the date on which the complaint was filed and on GCR 1963, 118.4 which requires that any amendment of the pleadings relates back to the date of the original pleading. ... As defendant notes, MCLA 600.6013; MSA 27A.6013, provides for interest on "any money judgment recovered". (Emphasis supplied.) Plaintiffs did not recover $150,000 from Efron. By accepting $65,000 in settlement, plaintiffs waived the right to statutory interest on that amount because no final judgment was rendered against the other defendants.

Section 600.6013 allows interest on a money judgment in a civil action from the date the complaint is filed, but it does not authorize interest on an arbitration award entered before a complaint is filed in circuit court.

Osinski v. Detroit Automobile Inter-Insurance Exchange · filed 1976-06-14

By its express terms § 6013 applies only to a money judgment recovered in a "civil action” and permits interest to accrue from the date of filing the complaint. A civil action is commenced only "by filing a complaint with the court”. GCR 1963, 101, MCLA 600.1901; MSA 27A.1901. In the instant case the arbitration proceedings were instituted by a filing of a claim for arbitration with the insurance company — not a complaint with the court. The pre-circuit court proceedings simply were not the equivalent of civil action, and therefore § 6013 does not authorize the payment or receipt of interest on an arbitration award entered prior to the filing of a complaint with the circuit court.

Section 600.6013's legally allowable interest rate applies by analogy to overdue alimony installments.

Stanaway v. Stanaway · filed 1976-07-21

This figure exceeds the legally-allowable interest rate on judgments permitted by MCLA 600.6013; MSA 27A.6013. This statute is, at the least, applicable to overdue alimony installments by analogy. Further, we cannot countenance a prospective pronouncement of interest in contemplation of default that necessarily ignores the factual circumstances that would attend any such future default. The "10% interest” provision must also be stricken from the judgment.

Section 600.6013 supports adding interest to the class recovery fund from July 21, 1965, the effective date of the statute.

Northview Construction Co. v. CITY OF ST CLAIR SHORES · filed 1976-12-30

We suggest that costs be taxed against the city and the city create a fund that is equal to the damages found to be due to those class members filing valid claims within the time limits established by the circuit court plus interest from July 21, 1965, the effective date of 1965 PA 240; MCLA 600.6013; MSA 27A.6013.

Section 600.6013 does not require interest on child-support arrearages in a divorce action; whether to award interest is left to the trial judge's discretion.

McClure v. McClure · filed 1977-05-17

The plaintiff contends that the trial court erred in not granting interest. She argues that MCLA 600.6013; MSA 27A.6013 mandates that interest shall be allowed on any money judgment. We are unable to find any Michigan precedent on this precise issue. ... It is the opinion of this Court that the awarding of interest on arrearage in a divorce action must be left to the sound discretion of the trial judge. ... The decision in Cyranoski v Keenan, supra, was decided prior to the enactment of the present statute, MCLA 600.6013; MSA 27A.6013. However, 1948 CL 623.20, which was effective at that time, is similar to present legislation for purposes of this discussion.

Section 600.6013 requires interest on a money judgment in a civil action to be calculated from the date the complaint was filed.

Linford Lounge, Inc. v. Michigan Basic Property Insurance · filed 1977-08-23

The standard policy does not specify the date from which interest on a judgment is payable. MCLA 600.6013; MSA 27A.6013, however, specifically states that interest shall be paid on a money judgment in any civil action from the date of filing the complaint. Obviously, a specific statute providing for interest controls a more general statute which specifies only when a loss is payable.

Section 600.6013 does not require interest from the date of filing the complaint when the judgment is an equitable remedy rather than a money judgment.

Moore v. Carney · filed 1978-07-05

We agree that under all the facts presented the judgment given is not a "money judgment” as that term is used in the statute.

Section 600.6013 requires interest on a money judgment in a civil action to be calculated from the date the complaint is filed, and its specific interest rule controls a more general insurance-policy timing provision.

Arkin Distributing Co. v. American Insurance · filed 1978-08-22

"MCLA 600.6013; MSA 27A.6013, however, specifically states that interest shall be paid on a money judgment in any civil action from the date of filing the complaint. Obviously, a specific statute providing for interest controls a more general statute which specifies only when a loss is payable. ... We hold that Linford Lounge, Inc is controlling in the instant case and that the trial court erred in granting pre-complaint interest to plaintiffs."

Section 600.6013 generally starts interest on a civil money judgment from the date the complaint is filed, but it does not control interest on a condemnation award.

City of Detroit v. Hopkins · filed 1979-08-21

Accordingly, we hold that MCL 600.6013; MSA 27A.6013 is not controlling in this case and that interest should not run from the date the complaint was filed but rather from the date of judgment or taking.

Section 600.6013's 6 percent judgment interest is inappropriate when an insurer accepts an appraisal award and pays the full award within 60 days, so judicial intervention and judgment entry are unnecessary.

O J Enterprises, Inc. v. Insurance Co. of North America · filed 1980-03-18

Defendant contends that the trial court erred in entering judgment in the amount of the appraisal award and in ordering that 6 per cent judgment interest, pursuant to MCL 600.6013; MSA 27A.6013, be paid on that award. We agree. ... Here the insurer acquiesced to the umpire’s decision and paid the full award within 60 days. In such cases, entry of a judgment accompanied by 6 per cent statutory interest is inappropriate.

Section 600.6013 sets the statutory interest rate on money judgments at 5% (at the time of the decree).

Meyering v. Russell · filed 1974-06-24

The statutory rate of interest allowed *706on money judgments at the time of the decree was 5%. MCLA 600.6013; MSA 27A.6013.

Section 600.6013 allows interest on a civil money judgment from the date the complaint was filed, including when an amended complaint merely removes settling defendants and adds no new damages or occurrences.

Oakwood Homeowners Ass'n, Inc. v. Marathon Oil Co. · filed 1981-03-17

"Interest shall be allowed on any money judgment recovered in a civil action, such interest to be calculated from the date of filing the complaint at the rate of 6% per year.”

Section 600.6013 provides for interest on money judgments recovered in civil actions, but does not apply to an equitable real estate lien in a divorce judgment unless the chancellor orders it.

Youmans v. Youmans · filed 1981-07-31

MCL 600.6013; MSA 27A.6013 provides for interest on any money judgment recovered in a civil action. This Court finds that an equitable real estate lien pursuant to a judgment of divorce is not a money judgment as contemplated by MCL 600.6013; MSA 27A.6013. Therefore, the statute has no application to an equitable suspension of a domestic partner’s share, unless the chancellor so orders.

Section 600.6013 provides statutory interest on a judgment rendered in the plaintiff’s favor, running here from the date of the complaint until the defendant paid the overcharges.

Huron Valley Steel Corp. v. Detroit Edison Co. · filed 1981-10-07

However, we cannot envision any policy or other reason for denying plaintiff statutory interest on the judgment under MCL 600.6013; MSA 27A.6013. As we have already held that the circuit court had jurisdiction of this action and that following the agency determination it entered judgment in conformity with the MPSC award of damages, there was a judgment rendered in plaintiff’s favor. As such, plaintiff was entitled to recover interest, and the trial court’s finding to the contrary constituted clear error.

Section 600.6013's judgment interest may be awarded together with the no-fault statute's 12% interest on overdue benefits; the two interest provisions are not mutually exclusive.

Wood v. Detroit Automobile Inter-Insurance Exchange · filed 1982-06-28

For the reasons given by the Court of Appeals, we hold that the provisions are not mutually exclusive and that the interest awards were proper.

Section 600.6013 supplies post-complaint interest on a judgment at 6% through June 1, 1980, and 12% thereafter until satisfaction, and that interest may be stacked with no-fault interest.

Allstate Insurance v. Citizens Insurance Co. of America · filed 1982-08-23

The interest figure included both 12% interest on the insurance claim computed from February 7, 1976, pursuant to the overdue claim provision of the no-fault act, MCL 500.3142(3); MSA 24.13142(3), and interest pursuant to MCL 600.6013; MSA 27A.6013. The latter amount is 6% from the date of the filing of the complaint through June 1, 1980, and 12% thereafter, until satisfaction of judgment. The stacking of interest is permissible.

Section 600.6013 mandates interest on a money judgment recovered in a civil action, but does not apply to a probate order awarding a widow's forced share of an estate.

In Re Cole Estate · filed 1982-10-18

However, the purpose of an award of interest pursuant to MCL 600.6013; MSA 27A.6013 is to compensate the prevailing party for the expenses incurred in bringing an action and for the delay in receiving money damages. Waldrop v Rodery, 34 Mich App 1, 4; 190 NW2d 691 (1971); Schwartz v Piper Aircraft Corp, 90 Mich App 324, 326; 282 NW2d 306 (1979); Wood v DAIIE, 99 Mich App 701, 709; 299 NW2d 370 (1980), rev'd in part on other grounds 413 Mich 573; 321 NW2d 653 (1982). An award of interest under MCL 600.6013; MSA 27A.6013 is mandatory in cases to which the statute applies. State Highway Comm v Great Lakes Express Co, 50 Mich App 170, 183; 213 NW2d 239 (1973). ... We therefore conclude that a probate court order awarding a widow a forced share of an estate pursuant to MCL 700.126; MSA 27.5126 is not a "money judgment recovered in a civil action" as that term is used in MCL 600.6013; MSA 27A.6013.

Section 600.6013 provides the basis for ordinary statutory interest on judgments.

Michigan Basic Property Insurance v. Michigan Mutual Insurance · filed 1983-01-10

The plaintiff is, however, entitled to the normal statutory interest on judgments under MCL 600.6013; MSA 27A.6013.

Section 600.6013 provides for judgment interest on an award from the filing of the complaint through payment.

Masco Corp. v. Kemper Insurance Group · filed 1983-01-20

This Court affirmed the award of judgment interest by the trial court on the insurance proceeds awarded pursuant to MCL 600.6013; MSA 27A.6013. We are of the opinion that the insured in this case is entitled to interest on the umpire’s award of $192,372.66 at 12% per annum from the date the original complaint was filed to the date of payment.

Section 600.6013 governs interest awarded on a judgment, rather than interest for the period before the action commenced.

Jaffe v. Harris · filed 1983-07-06

We agree with defendant Harris’s final objection that the trial court improperly awarded interest on the management fee claim for the period preceding commencement of the action. Interest should be awarded as interest on judgment. MCL 600.6013; MSA 27A.6013.

Section 600.6013 allows interest on a money judgment recovered in a civil action, but does not authorize interest on an award arising from administrative review rather than a civil action.

Oliver v. Department of State Police · filed 1984-03-05(1)

MCL 600.6013(1); MSA 27A.6013G) provides: "Interest shall be allowed on a money judgment recovered in a civil action, as provided in this section." ... This section is the exclusive interest provision in a civil action where a money judgment is recovered. ... The above cases suggest that interest is not proper in this action under MCL 600.6013; MSA 27A.6013. ... Interest under MCL 600.6013; MSA 27A.6013 is inappropriate.

For complaints filed before June 1, 1980, § 600.6013 applies 6% simple interest through May 31, 1980, and 12% interest compounded annually thereafter to the judgment plus interest accrued by June 1, 1980.

Gage v. Ford Motor Co. · filed 1984-04-02(2)

Applying the rule of the last antecedent, we conclude that the Legislature intended to apply the 6% simple interest as per the prior statute. The trial court correctly interpreted this aspect of the relevant subsection at issue. ... Based on the foregoing, this Court concludes that the 12% interest rate commencing June 1, 1980, applies to the amount of the judgment combined with interest which has accrued to that date at the 6% simple interest rate.

Subsection (4) requires statutory interest on a judgment, calculated from the date the complaint is filed, until the judgment is satisfied.

Osinski v. Yowell · filed 1984-06-18(4)

Plaintiffs shall collect 12% interest on the judgment, calculated from February 4, 1981, which is the date that the complaint was filed, and which shall continue until the judgment is satisfied. MCL 600.6013(4); MSA 27A.6013(4). Judgment interest is statutory and mandatory and is designed to compensate a party for its loss of use of its funds.

Section 600.6013 generally allows interest on money judgments from the date the complaint is filed in a civil action, including contract actions, but interest on claims accruing after filing is calculated from the later date payment was delayed.

University Emergency Services, PC v. City of Detroit · filed 1984-08-10

MCL 600.6013; MSA 27A.6013 provides that interest shall be allowed on a money judgment in a civil action "from the date of filing the complaint”. ... The county’s argument that statutory interest may not be awarded in contract actions lacks merit. The statute "applies to all damages sought and sustained in a civil action brought for the recovery of money damages”.

For complaints filed before June 1, 1980, the 12% annual compound interest rate applies to the judgment amount plus the 6% interest accrued through June 1, 1980.

Scott v. Allen Bradley Co. · filed 1984-10-04(2)

"For complaints filed before June 1, 1980, in an action involving other than a written instrument having a rate of interest exceeding 6% per year, the interest on the judgment shall be calculated from the date of filing the complaint to June 1, 1980 at the rate of 6% per year and on and after June 1, 1980 to the date of satisfaction of the judgment at the rate of 12% per year compounded annually."

Section 600.6013 allows interest only on money judgments recovered in a civil action, so a pre-judgment voluntary payment or settlement does not accrue statutory interest.

Darnell v. Auto-Owners Insurance · filed 1985-04-15

MCL 600.6013; MSA 27A.6013 specifically states that "interest shall be allowed on any money judgment recovered in a civil action * * *” (emphasis added). In the instant case, no judgment was rendered against Auto-Owners or the other insurance carrier for the sum involved. Auto-Owners voluntarily tendered the amount and State Farm voluntarily accepted it. Under these circumstances, § 6013 interest is not available to State Farm.

Section 600.6013(2)'s 12% interest calculation, as interpreted in Gage to compound interest on the balance owing as of June 1, 1980, does not apply retroactively to reopen a judgment after its satisfaction has been filed.

Gillispie v. Board of Tenant Affairs of the Detroit Housing Commission · filed 1985-09-03(2)

Prior to the Gage decision, there was considerable confusion as to whether the 12% should be compounded only on the original judgment or on the balance owing as of June 1, 1980., In Gage, this Court decided the question in favor of the latter interpretation. ... We believe it is clear that retroactive application of Gage would be inappropriate in the present case.

Section 600.6013(1) allows interest on a money judgment recovered in a civil action, but does not require statutory interest beyond the parties’ agreement when a consent judgment reflects a settlement silent on interest.

Young v. Robin · filed 1985-10-21(1)

Since a consent judgment is by definition a product of voluntary agreement, American Mutual, supra, it is not "recovered” through litigation of the matter to a judicial decision. ... The statute does not require defendants to pay more than the parties agreed. ... When the parties have reached no agreement on the question of interest, the trial court lacks authority to impose it as a term of the consent judgment.

Section 600.6013 allows statutory interest on a civil money judgment, and when part of the damages has been settled, the interest-bearing judgment is calculated on the remaining damages rather than the settled amount.

Harvey v. Security Services, Inc · filed 1986-01-07

The trial court in this action properly amended the original order of judgment by deducting the $300,000 settlement from the $939,000 jury award before recalculating the statutory interest. The statutory interest was therefore based on the remaining amount of damages. ... When plaintiff accepted the $300,000 settlement, he waived his right to statutory interest on that amount of the total damages awarded by the jury. ... See MCL 600.6013; MSA 27A.6013, which provides that interest shall be allowed on a money judgment recovered in a civil action, as provided in this section.

Section 600.6013 requires interest on money judgments recovered in a civil action, but does not authorize interest on a back-pay award entered by a commission proceeding that was not commenced by filing a complaint with a court.

Department of Civil Rights v. Horizon Tube Fabricating, Inc · filed 1986-02-03

MCL 600.6013; MSA 27A.6013 provides that interest "shall be allowed on any money judgment recovered in a civil action”. ... Because §6013 is in derogation of the common law, which does not generally allow interest on judgments, it must be strictly construed. ... In the instant case, the proceedings were instituted by filing charges with the Civil Rights Commission, not by a complaint with the circuit court. ... We conclude that the commission proceedings did not constitute a civil action and therefore § 6013 does not authorize the payment of interest on a back pay award entered by the commission.

Section 600.6013(4) does not apply its statutory interest rate to a foreclosure judgment ordering the sale of property; the contract rate governs the amount owed under the land contract, while statutory interest may apply to a later deficiency judgment.

Stewart v. Isbell · filed 1986-10-06(4)

The issue presented here is whether a judgment of foreclosure is a money judgment recovered in a civil action for purposes of the interest statute, MCL 600.6013; MSA 27A.6013. We hold that it is not. For purposes of the interest statute, a money judgment is defined as one which adjudges the payment of a sum of money, as distinguished from an order directing an act to be done or property to be restored or transferred. Moore v Carney, 84 Mich App 399, 404; 269 NW2d 614 (1978), quoting from Black’s Law Dictionary (4th ed), p 980. See also, 14 Callaghan’s Michigan Civil Jurisprudence, Interest, § 13, p 478. Under this definition, the judgment of foreclosure was not a money judgment because it ordered the sale of property in order to satisfy the amount owed under the land contract.

Section 600.6013 governs interest on a reimbursement order in an unsuccessful condemnation proceeding because it is the general interest statute applicable to civil actions.

Escanaba & Land Superior Railroad Co. v. Keweenaw Land Association · filed 1986-12-16

We believe that this statute does not apply to awards of attorney fees for unsuccessful condemnation proceedings under MCL 213.66(2); MSA 8.265(16)(2). Therefore, we conclude that the interest statute applicable to defendants’ reimbursement order is MCL 600.6013; MSA 27A.6013, the interest statute applicable to all civil actions, and remand to the trial court for computation of interest as so determined.

Section 600.6013 permits prejudgment interest to compensate a prevailing party for litigation expenses and delay in receiving money damages.

In Re Irwin Estate · filed 1987-05-27

In this case, unlike in In re Thacker Estate, supra, Mason specifically claims that Bessie Irwin's estate is entitled to prejudgment interest pursuant to MCL 600.6013; MSA 27A.6013 for the amounts she erroneously paid to appellant, pursuant to his advice, prior to court approval of his fees. We agree. The purpose of MCL 600.6013; MSA 27A.6013 is to compensate the prevailing party for expenses incurred in bringing an action and for delay in receiving money damages. ... In this case, appellant was ordered to pay a money judgment. He was not ordered to do any further acts.

Section 600.6013 requires interest on a money judgment in a civil action from the date the complaint is filed.

Marina Bay Condominiums, Inc v. Schlegel · filed 1988-04-04

MCL 600.6013; MSA 27A.6013 provides that interest is to be paid on a money judgment in a civil action from the date the complaint is filed. The allowance of interest under this statutory provision is mandatory. ... A "money judgment” is one which adjudges the payment of a sum of money as distinguished from directing an act to be done. ... In light of the statute’s mandatory language providing for payment of interest on money judgments in civil actions, we conclude that the trial court’s award of interest to plaintiff on the $2,600 money judgment was proper.

Section 600.6013(4) requires interest on qualifying money judgments from the filing of the complaint through satisfaction at 12% per year compounded annually, and absent a contractual provision the statutory prejudgment-interest obligation applies only to the insurer's policy limits.

Cochran v. Myers · filed 1988-06-07(4)

In the present insurance policy Auto Club did not provide for payment of any prejudgment interest. Rather, the insurance policy provided for payment of all interest on the entire amount of any judgment which accrues after the entry of judgment. Due to the fact that there was no contractual provision in the insurance policy, the statutory requirement that prejudgment interest be paid on the policy limits alone must be applied.' In this case, the trial court properly determined that Auto Club was obligated to pay prejudgment interest on the $50,000 policy limit only.

Section 600.6013(1) governs interest in civil actions and does not apply to circuit court review of Civil Service Commission actions.

Tenbusch v. Department of Social Services · filed 1988-10-17(1)

Circuit court review of actions of the commission is not a civil action within the meaning of MCL 600.6013(1); MSA 27A.6013(1).

For complaints filed before January 1, 1987, judgment interest runs from filing to satisfaction at 12% compounded annually and is calculated only on sums awarded in the money judgment, not amounts accepted in a pre-judgment settlement.

Bloemsma v. Auto Club Insurance · filed 1989-02-07(4)

By statute in Michigan, for complaints filed before January 1, 1987, judgment interest shall be calculated from the "date of filing the complaint to the date of satisfaction of the judgment at the rate of 12% per year compounded annually . . . .” MCL 600.6013(4); MSA 27A.6013(4). MCL 600.6013(4); MSA 27A.6013(4) specifically requires that the judgment interest be calculated on a sum awarded in a money judgment. Judgment interest is not calculated on amounts an injured party voluntarily accepts from a no-fault insurance carrier in settlement before judgment.

Section 600.6013 mandates interest on money judgments in civil actions to compensate the prevailing party for delay in receiving money damages.

McCahill v. Commercial Union Insurance · filed 1989-09-05(1), (4)

The purpose of an award under this section is to compensate the prevailing party for delay in receiving money damages. ... This section providing for payment of interest on all money judgments entered in civil actions is mandatory and not permissive.

Section 600.6013 authorizes postjudgment interest on a consent judgment from entry of judgment until the judgment is paid in full, unless the judgment limits the interest or the plaintiff waives it.

Madison v. City of Detroit · filed 1990-03-19(4)

The entry of the judgment by the circuit court not only gave judicial approval to the settlement with the estate, but also commenced the running of interest on the judgment. The judgment at issue contains no provision to stay its enforcement or toll its interest. Accordingly, in lieu of a waiver by the plaintiffs, satisfaction of the judgment is expected within twenty-one days, MCR 2.614(A)(1), and interest runs until the judgment is paid in full. MCL 600.6013; MSA 27A.6013. ... In this instance, postjudgment interest is authorized by statute. Since the award of such interest was neither limited by the judgment nor waived by the plaintiffs, we hold that the lower court clearly erred by denying plaintiffs’ motion for postjudgment interest.

Section 600.6013 requires interest on a money judgment in a civil action, including prejudgment interest from the complaint’s filing when a court enters judgment after the parties stipulate to arbitration during the action.

Old Orchard by the Bay Associates v. Hamilton Mutual Insurance · filed 1990-03-20(3), (5)

We reject that argument and reverse the decision of the Court of Appeals on the interest issue and hold as follows: (1) where the parties to a contract dispute have no agreement to arbitrate, and (2) do not later stipulate to an interest entitlement or rate (assuming the original action is not dismissed),6 (3)(a) statutory interest is awardable on the judgment from the date of the filing of the complaint until the judgment is entered, and (b) such interest is also awardable thereafter until the judgment is paid, as provided in MCL 600.6013; MSA 27A.6013.

Section 600.6013 governs interest from the filing of a civil complaint to confirm an arbitration award until the resulting judgment is satisfied.

Gordon Sel-Way, Inc. v. Spence Bros. · filed 1991-09-17(1)

Thus, we reverse the decision of the Court of Appeals on this issue and hold that MCL 600.6013; MSA 27A.6013 governs the award of interest from the date a complaint is filed requesting confirmation of an arbitration award and continues until the judgment rendered on the award is satisfied.

Section 600.6013(4) allows prejudgment interest on a money judgment from the date the complaint is filed through the date the judgment is satisfied.

Sullivan Industries, Inc. v. Double Seal Glass Co. · filed 1991-12-27(4)

MCL 600.6013(4); MSA 27A.6013(4) allows prejudgment interest on a money judgment from the date of filing the complaint to the date of satisfaction of the judgment.

Section 600.6013 generally runs prejudgment interest from the filing of the complaint until satisfaction of the judgment, but permits disallowing interest for delay not caused by the debtor.

Eley v. Turner · filed 1992-03-11

MCL 600.6013; MSA 27A.6013 provides that interest is to be paid on money judgments from the date the complaint is filed to the date of satisfaction of the judgment. This Court has held that a court may disallow prejudgment interest for periods of delay where the delay was not the fault of, or caused by, the debtor. ... The circuit court held that the delay from February 25, 1986, to August 28, 1987, was not the fault of, or caused by, defendants and that they should not be charged interest for that period of time. We find no error in the circuit court’s ruling.

Section 600.6013 provides prejudgment interest to compensate the prevailing party for litigation expenses and delay in receiving money damages.

Mason v. Campbell · filed 1987-05-27

The purpose of MCL 600.6013; MSA 27A.6013 is to compensate the prevailing party for expenses incurred in bringing an action and for delay in receiving money damages.

Section 600.6013(4) requires twelve percent interest on an alimony-in-gross judgment from the filing of the complaint through satisfaction of the judgment.

Cropsey v. Scranton · filed 1993-02-17(4)

Accordingly, we find that reversal is warranted on this basis and that plaintiff is entitled to twelve percent interest on the award of alimony in gross calculated from the date of the filing of the complaint through the date of satisfaction of the judgment, pursuant to MCL 600.6013(4); MSA 27A.6013(4).

Section 600.6013 provides for interest on a judgment when the plaintiff is entitled to that judgment.

DeMeglio v. Auto Club Ins Ass'n · filed 1993-11-02

Plaintiff also contends that the circuit court erred in denying plaintiff interest on overdue benefits pursuant to MCL 500.3142; MSA 24.13142 and on the judgment pursuant to MCL 600.6013; MSA 27A.6013. Defendant agrees that, if plaintiff is entitled to the judgment, she is also entitled to interest pursuant to those sections. We also agree.

Section 600.6013 requires interest on the conversion damages to be awarded at the applicable legal rate and adjusted for the relevant time periods.

Ehman v. Libralter Plastics, Inc · filed 1994-09-20

We agree that the court erred in failing to award interest in conformity with MCL 600.6013; MSA 27A.6013 and MCL 438.31; MSA 19.15(1).

Section 600.6013 allows interest on money judgments but excludes future damages from pre-judgment interest for complaints filed on or after October 1, 1986; in calculating mediation sanctions, interest is limited to the period and damages permitted by the specific court rule.

Frank v. William a Kibbe & Associates, Inc · filed 1995-01-17(1)

Consequently, the term "assessable costs and interest” in MCR 2.403(G)(3), when read in conjunction with MCL 600.6013; MSA 27A.6013 means interest which properly can be assessed under MCL 600.6013; MSA 27A.6013. Since interest may not be assessed on the portion of the verdict which represents future damages, the trial court erred in assessing interest on the full amount of the award. ... MCR 2.403 also limits the period during which interest may be assessed to the time between the filing of the complaint and the date of the mediation evaluation. Although MCL 600.6013; MSA 27A.6013 permits interest to be assessed to the date of entry of judgment, we believe that the specific requirement set forth in the court rule controls.

Section 600.6013(2) requires statutory interest on covered money judgments to accrue from the complaint's filing through satisfaction, with a payment stopping interest only for the amount paid.

Hadfield v. Oakland County Drain Commissioner · filed 1996-09-27(2)

MCL 600.6013(2); MSA 27A.6013(2) specifically states that interest accrues on money judgments from the time the complaint was filed: ... Therefore, imposition of statutory interest pursuant to MCL 600.6013; MSA 27A.6013 is mandatory and interest must be paid from the date the complaint was filed. ... Statutory interest accrues until the judgment is satisfied. MCL 600.6013(2); MSA 27A.6013(2). ... However, payment to the clerk stops the accrual of interest only with respect to the portion paid, not the entire amount later determined to be due.

Section 600.6013(1) requires statutory interest on a money judgment recovered in a civil action, and a judgment ordering payment of seized money in an in rem forfeiture proceeding qualifies as a money judgment.

In Re FORFEITURE OF $176,598 · filed 2000-10-31(1)

MCL 600.6013(1); MSA 27A.6013(1) provides in pertinent part, “Interest shall be allowed on a money judgment recovered in a civil action, as provided in this section.” ... This case involves a civil action, because a forfeiture proceeding is an in rem civil proceeding. ... Thus, the question presented is whether the judgment at issue constitutes a “money judgment” under MCL 600.6013(1); MSA 27A.6013(1). ... As such, we conclude that it qualifies as a “money judgment” for purposes of MCL 600.6013(1); MSA 27A.6013(1).

Section 600.6013 governs interest on a civil judgment from the date the complaint is filed until the judgment is satisfied.

National Union Fire Insurance v. Richman · filed 1994-05-03

Afterward, MCL 600.6013; MSA 27A.6013 governs the award of interest until the judgment is satisfied.

Section 600.6013(8) requires interest at the statutory variable rate from the date the complaint is filed through judgment, and governs interest thereafter until the judgment is satisfied.

R.D. Management Corp. v. Philadelphia Indemnity Insurance · filed 2004-02-17(8)

Nonetheless, the Court believes that the rule of that case requires the Court to calculate interest from the date the complaint was filed through the date of judgment in accordance with Mich. Comp. Laws § 600.6013(8) at the variable rate described therein.

Section 600.6013 requires interest to continue accruing until the judgment is satisfied; a tender made while the debtor pursues an appeal does not satisfy the judgment.

Amerisure Ins. Co. v. Auto-Owners Ins. Co. · filed 2004-07-21

Under MCL 600.6013, interest accrues until a judgment is satisfied. ... Here, Amerisure's tender of payment was not in fact a satisfaction of the judgment because it *403 chose to pursue an appeal. Accordingly, the interest provisions apply.

Section 600.6013(1) allows interest on a money judgment recovered in a civil action, including an insurance judgment for benefits determined through appraisal.

Angott v. Chubb Group of Insurance Companies · filed 2006-06-12(1)

MCL 600.6013(1) provides, “Interest is allowed on a money judgment recovered in a civil action, as provided in this section.” “For the purpose of the judgment interest statute, a money judgment is one that orders the payment of a sum of money, as distinguished from an order directing an act to be done or property to be restored or transferred.” ... There can be no reasonable dispute that the trial court entered a money judgment ordering defendant to make payment of a sum of money under the policy and that the judgment controlled defendant’s financial obligations and plaintiffs financial entitlements under the policy. Furthermore, our ruling that plaintiff is entitled to the full amount of the appraisal award, $1,058,750, similarly requires the entry of a “money” judgment on remand. Under the clear and unambiguous language of MCL 600.6013, plaintiff is entitled to prejudgment interest.

For a confirmed statutory arbitration award, interest at the rate provided by § 600.6013 runs from the date of the arbitration award until the judgment is satisfied.

Uhl v. Komatsu Forklift Co., Ltd. · filed 2006-12-08

It is further ORDERED that the plaintiff and intervening plaintiff shall recover interest at the rate set forth in Michigan Compiled Laws section 600.6013 from and after September 12, 2006 until the judgment is satisfied.

Section 600.6013(8) provides interest on a judgment from the filing of the complaint through satisfaction and supplies the applicable postjudgment interest after judgment is entered, including when the judgment includes no-fault penalty interest.

Bonkowski v. Allstate Insurance · filed 2008-10-02(8)

MCL 600.6013(8) expressly entitles plaintiff to interest on the judgment (6 percent in this case) accruing from the date the complaint was filed through the date the judgment is satisfied. That interest is awarded on a judgment that includes the 12 percent interest the jury awarded as penalty interest. However, once the judgment is entered, postjudgment interest is limited to the interest rate applicable under the RJA. MCL 600.6013(8).

Section 600.6013(8) requires prejudgment interest on the entire money judgment, including actual and consequential damages, calculated from the date the complaint was filed.

City of Sterling Heights v. United National Insurance Comp · filed 2009-03-31(8)

The district court also correctly awarded prejudgment interest, which is based “on the entire amount of the money judgment,” Mich. Comp. Laws § 600.6013(8). A “money judgment” includes any judgment that “orders the payment of a sum of money, as distinguished from an order directing an act to be done or property to be restored or transferred.” ... Courts must award prejudgment interest “in all cases to which the statute applies.” ... The City’s “money judgment” properly includes the actual-damages and consequential-damages awards. Both orders directed United to pay a sum of money, and the Michigan interest statute by its terms gave the City a right to prejudgment interest on both.

Section 600.6013(8) requires interest on a money judgment to be recalculated every six months from the complaint-filing date using the rate announced on whichever January 1 or July 1 immediately precedes each six-month calculation date.

Chelsea Investment Group LLC v. City of Chelsea · filed 2010-04-27(8)

In our view, the language of this provision is plain and unambiguous. It requires that “interest on a money-judgment . .. [be] calculated at 6-month intervals from the date of the filing of the complaint at a rate of interest equal to 1% plus the average interest rate [of] . . . United States treasury notes during the 6 months immediately preceding July 1 and January 1. .. .” When this language is parsed, MCL 600.6013(8) simply requires that interest on a judgment be recalculated every six months from the date of the filing of the complaint using the interest rates announced on July 1 or January 1, whichever is “immediately preceding” the complaint’s six-month calculation date. For example, interest for a complaint filed in August 2008 would be calculated in February 2009 using the January 1, 2009, rate, and would be calculated again in August 2009, using the July 1, 2009, rate.

Section 600.6013(8) provides prejudgment interest on civil money judgments, calculated from the complaint date at the statutory interval rate, compounded annually, on the full money damage including attorney fees and other costs.

Mais v. Allianz Life Insurance Co. of North America · filed 2014-07-22(8)

Michigan Compiled Laws § 600.6013 provides for pre-judgment interest on money judgments in civil actions. ... Applying the applicable interval interest rates and statutory one percent, compounded annually, Mais is entitled to $11,605.53 in prejudgment interest.

Section 600.6013 governs interest on a money judgment in a civil action.

Dollen v. Dollen · filed 2014-11-13

However, that statute was clearly not applicable to the current case, as it governs interest on a money judgment in a civil action. The cases defendant cited simply held that a divorce judgment was not a money judgment in a civil action contemplated under MCL 600.6013. The cases did not at all state that a divorce judgment was not a money judgment.

Section 600.6013(1) allows statutory interest on a money judgment recovered in a civil action, not on a judgment in a probate proceeding.

in Re Easterly Estate · filed 2015-05-14(1)

We also find merit to appellant’s argument that the probate court erred in treating the sanctions award as a civil judgment, subject to statutory interest commencing as of October 30, 2013. MCL 600.6013(1) provides that “[i]nterest is allowed on a money judgment recovered in a civil action, as provided in this section.” Here, the current matter was not a civil action, but rather a probate court proceeding.

Section 600.6013 allows interest on a money judgment recovered in a civil action, but does not apply to an order requiring a defendant who merely defended an action to pay the opposing party's attorney fees and costs.

Lech II v. Huntmore Estates Condominium Association · filed 2016-04-26(1) (8)

MCL 600.6013(1) provides that “[i]nterest is allowed on a money judgment recovered in a civil action, as provided in this section.” ... A money judgment in a civil action is a judgment “that orders the payment of a sum of money, as distinguished from an order directing an act to be done or property to be restored or transferred.” ... We conclude that, by its plain language, MCL 600.6013 does not apply in such circumstances, and Ayar does not mandate a different result.

Subsection (7) applies only when the judgment is rendered on a written instrument with a specified interest rate; otherwise, interest on a civil money judgment is calculated under subsection (8).

Wyandotte Electric Supply Co. v. Electrical Technology Systems, Inc. · filed 2016-05-03(7) and (8)

This restrictive term requires the written instrument to be the actual basis of the judgment for MCL 600.6013(7) to apply. ... Because judgment was not rendered on a written instrument at all, we need not address whether the written instrument in this case evidenced indebtedness at a specified interest rate. Interest on the judgment should instead be calculated under MCL 600.6013(8), the general rule for interest on a money judgment in a civil case.

Section 600.6013 provides prejudgment interest on money judgments in civil actions, but it does not determine an insurer’s liability for that interest; the insurance policy governs.

Luczak v. Corey a Drielick · filed 2017-12-14(8)

MCL 600.6013 is remedial and primarily intended to compensate prevailing parties for expenses incurred in bringing suits for money damages, and for any delay in receiving such damage. ... We agree that MCL 600.6013 does not speak to an insurer’s liability for prejudgment interest; however, we disagree with Empire’s assertion that it is not obligated to pay prejudgment interest under the terms of the policy at issue in this case.

Section 600.6013(1) allows interest on a money judgment recovered in a civil action, but does not apply to an equitable order compensating parties to restore property interests when the award lacks a nexus to a pleaded claim.

Jode Investments LLC v. Burning Tree Properties LLC · filed 2018-02-27(1)

MCL 600.6013(1) states, in pertinent part, that “[i]nterest is allowed on a money judgment recovered in a civil action, as provided in this section.” ... This issue comes down to whether the judgment at issue is indeed a “money judgment” as contemplated in the statute. ... However, merely because a judgment awards money, it does not necessarily follow that the judgement is a “money judgment.” ... Here, this Court ordered that the owners of BTI be compensated for the (wrongful) transfer of BTI’s property to Club Golf, which would restore defendants’ position to where it had been before the transfers took place. ... The lack of a nexus between defendants’ counter-complaint and their judgment award is fatal when seeking interest under MCL 600.6013.

Section 600.6013(1) allows interest on a money judgment recovered in a civil action, but it does not apply when the judgment merely restores money or property wrongfully transferred and is not a money judgment.

Jode Investments LLC v. Burning Tree Properties LLC · filed 2020-02-20(1)

MCL 600.6013(1) states, in pertinent part, that “[i]nterest is allowed on a money judgment recovered in a civil action, as provided in this section.” ... Although the September 30, 2016 order directed the payment of money to Jode Investments, Mauro, DiMercurio, and Gesuale, the order was not a “money judgment” for purposes of MCL 600.6013. ... Because the nature of the September 30, 2016 order of judgment remains the same, i.e., not a “money judgment” for purposes of MCL 600.6013, the trial court abused its discretion when it allowed defendants to seek postjudgment interest in the writs of garnishment.

Subsection (8) uses the same statutory method to calculate both prejudgment and post-judgment interest; it does not distinguish between them.

VanderKodde v. Mary Jane M. Elliott, P.C. · filed 2020-02-26(8)

But MCL § 600.6013(8) makes no distinction between pre-judgment interest and post-judgment interest. Both are calculated in the exact same way.

Section 600.6013(8) requires statutory interest on the entire money judgment, including attorney fees.

Houle v. Emc Development · filed 2021-05-20(8)

The italicized language, “Interest under this subjection is calculated on the entire amount of the money judgment, including attorney fees,” clearly establishes that interest accrues on attorney fees.

Section 600.6013(8) provides that interest on a civil money judgment is calculated from the date the complaint is filed and includes attorney fees and other costs.

Bradley v. Frye-Chaiken · filed 2022-07-14(8)

MCL 600.6013(8) plainly states that interest on a money judgment in a civil case is calculated from the date that the complaint is filed. And MCL 600.6013(8) specifically includes attorney fees and other costs.

Section 600.6013(8) requires interest on a money judgment to be calculated from the date the complaint was filed.

City of Bad Axe v. Pamar Enterprises Inc · filed 2022-07-21(8)

MCL 600.6013(8) “plainly states that interest on a money judgment is calculated from the date of filing the complaint.”

Subsection (1) allows prejudgment interest on a money judgment but excludes interest on future damages from the filing of the complaint to entry of judgment.

Glowacki v. O'Reilly Auto Enterprises, LLC · filed 2023-12-14(1)

To the contrary, that section expressly allows prejudgment interest on damages in a money judgment, but it excludes interest on future damages. ... Accordingly, under Mich. Comp. Laws § 600.6013(1) & (8) the Court will award Glowacki prejudgment interest—accruing from October 7, 2021, up to the date of the Court’s judgment on March 15, 2023—on his attorney’s fees and costs, on his past economic damages (back pay, lost stock options) and on his non-economic damages (emotional distress).

Section 600.6013 makes statutory prejudgment interest mandatory on a prevailing party’s money judgment, even if the judgment order does not expressly provide for it.

Bowles v. Repkie · filed 2025-04-18

Bowles argues about prejudgment interest. It is mandatory according to statute. See Alpine Constr Co v Gilliland Constr Co, 50 Mich App 568, 574; 213 NW2d 824 (1973), and MCL 600.6013. “A prevailing party is entitled to the statutory interest on his money judgment even though the order of judgment did not expressly provide for interest.” Dep’t of Treasury v Central Wayne Co Sanitation Auth, 186 Mich App 58, 64; 463 NW2d 120 (1990). We remind the trial court of this because the court stated that it was not going to award prejudgment interest.

Section 600.6013 provides that interest on a money judgment accrues from the complaint date under the statutory Treasury-note-based formula, calculated on the judgment amount, but prejudgment interest cannot be assessed on attorney fees awarded under the MCPA.

Mannion · filed 2026-01-29(8)

Under Mich. Comp. Laws § 600.6013, interest shall be allowed on a money judgment in any civil action and is deemed to have begun accruing on the date the complaint was filed. Jones, 819 F. Supp. at 1383. Under that provision, “for complaints filed on or after January 1, 1987, interest on a money judgment recovered in a civil action is calculated at 6-month intervals from the date of filing the complaint at a rate of interest equal to 1% plus the average interest rate paid at auctions of 5-year United States treasury notes during the 6 months immediately preceding July 1 and January 1, as certified by the state treasurer, and compounded annually, according to this section. Interest under this subsection is calculated on the entire amount of the money judgment, including attorney fees and other costs.” Mich. Comp. Laws § 600.6013(8). However, “prejudgment interest pursuant to MCL 600.6013; . . . [can]not be assessed on attorney fees awarded under the MCPA.” Smolen v. Dahlmann Apartments, Ltd., 186 Mich. App. 292, 299 (1990).

Section 600.6013(8) requires prejudgment interest to run from the complaint-filing date and be calculated on the entire money judgment, including attorney fees and costs, even when damages accrue later.

LinTech Global, Inc. v. CAN Softtech, Inc. · filed 2026-02-27(8)

Under Michigan law, statutory interest runs “from the date of filing the complaint” and “is calculated on the entire amount of the money judgment, including attorney fees and other costs.” Mich. Comp. Laws § 600.6013(8). Section 600.6013 “is remedial in nature and is to be construed liberally in favor of the prevailing party.” ... As in Perceptron and Seton, here the actual legal wrong (tortious interference) predated the filing of the Complaint. Thus, prejudgment interest, calculated on the full award, runs from the filing of the Complaint even if Defendants were paid by the FAA thereafter.

Section 600.6013(1) generally does not require interest on a divorce judgment because a divorce judgment is not a money judgment under the statute.

Elturk v. Elturk · filed 2026-06-15(1)

A divorce judgment is not a money judgment within the meaning of the interest statute and does not normally carry interest under MCL 600.6013(1).

Section 600.6013(8) requires judgment interest to be recalculated at six-month intervals from the complaint date using the interest rate announced immediately before each calculation date, and includes qualifying attorney fees and costs in the judgment amount on which interest accrues from the complaint date.

Cadwell v. City of Highland Park · filed 2019-02-19(8)

Thus, in the instant case, the first period begins on October 20, 2010, which is the date the complaint was filed. The first period ends six months later, in April 2011. The applicable interest rate is the rate announced on January 1, 2011, which falls between the beginning date and calculation date of the period.

Section 600.6013(2) requires interest on the full trebled recovery from the complaint date, at 6% until June 1, 1980 and 12% thereafter, compounded annually until payment.

Bass v. Spitz · filed 1981-09-18(2)

These purposes are best served by allowing interest on the full trebled amount of plaintiff’s recovery. ... The 1980 amendment was intended to insure full compensation by providing an adequate rate of interest. I believe that compounded interest from the date of the complaint is more consistent with this goal. ... In summary, plaintiff may recover interest on the judgment at the rate of 6% per annum from the date of filing of the complaint to June 1, 1980 and thereafter until the judgment is paid at the rate of 12% per annum, compounded annually.

Section 600.6013 does not apply to divorce judgments; interest in those judgments is within the circuit court’s equitable discretion.

Richards v. Richards · filed 2005-03-31

This is because of a peculiarity in Michigan’s statutory interest statute, Mich. Comp. Laws § 600.6013, which has been interpreted as not applying to divorce judgments.

Section 600.6013 applies only when a judgment has been entered, and an amendment increasing its interest rate does not apply retroactively to rights already determined.

White v. Extra Labor Power of America · filed 1974-07-23

We find MCLA 600.6013; MSA 27A.6013 to have no application in the case at bar since it applies only to judgments and no judgment has been entered here. Further it should be noted that the amendment to this statute raising the rate from five percent to six percent did not become effective until March 30, 1973, and can have no retroactive effect on rights already determined.

Section 600.6013(1) does not require interest on attorney fees and costs awarded ancillary to a divorce judgment because that award is not a money judgment recovered in a civil action; payment under a supersedeas bond does not change the result.

Olson v. Olson · filed 2007-03-14(1)

Here, as in In re Forfeiture, the trial court’s order for payment of the attorney fees was not an adjudication of an action for money damages. The fact that the court subsequently ordered payment under the supersedeas bond does not change the underlying character of the order for payment or mandate a different result with respect to § 6013. Accordingly, we conclude that plaintiff is not entitled to a mandatory award of interest under § 6013(1) on the award of attorney fees and costs in the divorce action.

Section 600.6013(1) applies to money judgments recovered in civil actions, not to divorce judgments.

Chew v. Lopez · filed 2024-04-25(1)

MCL 600.6013(1) applies to money judgments recovered in a civil action.

Section 600.6013 requires interest to be computed from the date the complaint or suit was commenced.

Cates v. Moyses · filed 1975-01-07

Interest is to be computed as of the date the complaint was filed, MCLA 600.6013; MSA 27A.6013. When Cosby, supra, stated that an insurance company can limit its risks, it was discussing only the issue of the amount on which the company’s interest liability would be based, not the date the interest was to begin. In its holding on the date issue, the Cosby court held that the statute requiring interest to be computed as of the date suit was commenced replaced the contrary policy provision and that therefore the statute superseded the interest clause of the policy. Again we affirm the circuit court and hold that interest shall be computed from the date of commencement of suit.

Section 600.6013 requires prejudgment interest on the judgment to be calculated from the date the complaint was filed.

Dittus v. Geyman · filed 1976-04-06

By virtue of MCLA 600.6013; MSA 27A.6013, defendant is required to pay interest on the judgment from the date of the complaint.

Section 600.6013 requires prejudgment interest on a civil money judgment to be calculated from the date the complaint is filed, while excluding future personal-injury damages from that calculation.

Venture Industries Corp. v. Autoliv ASP, Inc. · filed 2006-08-07(1) and (6)

Autoliv argues that prejudgment interest in this case should not be calculated from the time the complaint was filed. ... In view of the arguments made, we agree with Venture that damages in this case should have been calculated from the date the complaint was filed rather than when the damages accrued. ... In this case, the proper date to calculate prejudgment interest is the date of filing the complaint.

Section 600.6013 provides statutory interest on a judgment from the date the complaint is filed, while § 438.7 governs prejudgment interest on a fixed and ascertainable contract loss.

Ramada Development Company, a Corporation v. United States Fidelity & Guaranty Company, a Corporation · filed 1980-06-10

However, while MCLA § 600.6013 does require that interest on a judgment be calculated from the date of filing the complaint, all of the cases cited by appellee invoking § 600.6013 are cases where the damages were unliquidated before final judgment — usually tort cases. We think that the relevant statute for the instant case is MCLA § 438.7.

Section 600.6013 requires interest from the date the complaint is filed, without an exception based on the liable party’s good faith in denying liability.

Johnston v. Detroit Automobile Inter-Insurance Exchange · filed 1983-01-25

Defendant claims that prior to the LeBlanc decision it had no liability to pay medical benefits for which plaintiff had been reimbursed by Medicare and thus it is not required to pay interest on any amounts withheld prior to the LeBlanc decision. However, § 6013 directs that interest shall be allowed from the date of filing the complaint. There is no qualification as to the good faith with which one found liable denied liability.

Section 600.6013 permits interest to be computed from the date the original complaint was filed, even when the defendant was added later by amendment.

Gagnon v. Dresser Industries Corp. · filed 1983-09-01

Although MCL 600.6013; MSA 27A.6013 authorizes a trial court to add interest "from the date of filing the complaint”, the statute does not differentiate between original filing and an amendment which adds a new party defendant.

Section 600.6013(4) generally awards interest from the complaint's filing through satisfaction, but when the claim arose after the original complaint, interest runs from the date of delay rather than the initial filing.

McKelvie v. Auto Club Ins Ass'n · filed 1994-01-19(4)

We accept that § 6013 is a remedial statute that is to be construed liberally in favor of a plaintiff. ... However, we do not believe that a plaintiff is entitled to collect interest from the date of filing the initial complaint on a claim that did not arise until well over two years after the initial complaint was pled. Such an award exceeds the purpose of compensating for a delayed payment, overcompensates for the related litigation, and departs from the purpose of providing an incentive for prompt settlement by both imposing a penalty upon the defendant and conferring a favor upon the plaintiff. Such a result was not permitted at common law, and we are not persuaded that the Legislature intended such a result under § 6013. ... Under the facts of this case, we do not believe that the trial court erred as a matter of law in awarding interest from the date of delay.

Section 600.6013 entitles a prevailing party in a civil action to prejudgment interest from the filing of the complaint through entry of judgment, and the statute is construed liberally in favor of the plaintiff.

H J Tucker & Associates, Inc. v. Allied Chucker & Engineering Co. · filed 1999-03-26

MCL 600.6013; MSA 27A.6013 entitles a prevailing party in a civil action to prejudgment interest from the date of filing the complaint to the entry of the judgment. The purpose of prejudgment interest is to “compensate the prevailing party for expenses incurred in bringing actions for money damages and for any delay in receiving such damages.” Phinney v Perlmutter, 222 Mich App 513, 541; 564 NW2d 532 (1997). “[T]he prejudgment interest statute is remedial in nature and is to be construed liberally in favor of the plaintiff.” Id.

Section 600.6013 supplies the 6% statutory rate used to discount future damages to present value.

Freeman v. Lanning Corporation · filed 1975-05-30

We note that this requires that the total award found by the trial judge be apportioned on a yearly basis and discounted at the statutory rate of 6 percent. MCLA 600.6013; MSA 27A.6013.

Section 600.6013's interest provision for money judgments in civil actions does not govern workers’ compensation awards, and the WCAB lacked authority to apply its 6% rate to those awards.

Solakis v. Roberts · filed 1975-09-08

In summary, the unilateral action of WCAB in Maxwell attempting to apply the interest rate of 6% found in MCLA 600.6013 was beyond the scope of the powers delegated to that body. This Court’s decision in Wilson trod the fine line separating the legislative and judicial branches of government.

Section 600.6013 does not apply to compulsory interest arbitration in the public sector because an Act 312 arbitration award is not a money judgment recovered in a civil action.

City of Detroit v. Detroit Police Officers Ass'n · filed 1980-06-06

MCL 600.6013, as part of the Revised Judicature Act of 1961, does not apply to compulsory interest arbitration in the public sector.

Section 600.6013 authorizes prejudgment interest, but it does not govern the interest rate or accrual period for an arbitration award.

Babayan v. Detroit Automobile Inter-Insurance Exchange · filed 1982-11-18

First, defendant contends that the trial court erred when it computed interest at 12% per annum from the date of the filing of the arbitration demand, under MCL 600.6013; MSA 27A.6013, rather than at 5% per annum from the date of the award, under MCL 438.31; MSA 19.15(1). We agree. The allowance of interest in general is statutory and the allowance of interest in arbitration awards is governed by MCL 438.7; MSA 19.4 and MCL 438.31; MSA 19.15(1).

Section 600.6013 allows interest only on money judgments recovered in civil actions through court proceedings, not on arbitration awards or judgments confirming them.

Morgan v. Kamil · filed 1985-03-19

MCL 600.6013; MSA 27A.6013 allows interest only on money judgments recovered in civil actions; it does not authorize interest on an arbitration award and ... the judgments entered confirming the award. The Legislature intended MCL 600.6013; MSA 27A.6013 to apply only to judgments obtained in civil actions, through court proceedings, not arbitration.

Section 600.6013 applies to money judgments recovered in a civil action and does not authorize interest on an arbitration award from the date of a pre-court arbitration demand.

Moultrie v. Detroit Automobile Inter-Insurance Exchange · filed 1983-02-23

"By its express terms § 6013 applies only to a money judgment recovered in a 'civil action’ and permits interest to accrue from the date of filing the complaint.

Section 600.6013 authorizes interest, including prejudgment interest, only on money judgments recovered through court proceedings, not on arbitration awards or judgments confirming them.

Western Casualty & Suretty Co. v. City of Garden City · filed 1986-04-21

In a similar issue, Garden City argues that the trial court erred in awarding Western statutory interest on its order of judgment. Once again the recent holding by this Court in Morgan v Kamil, supra, is instructive. MCL 600.6013; MSA 27A.6013 does not authorize interest on an arbitration award. 144 Mich 173. Interest on an arbitration award in an action founded on a contract is governed by MCL 438.7; MSA 19.4.

Section 600.6013 allows interest only on money judgments recovered in civil actions through court proceedings, not on arbitration awards or judgments confirming them.

Gordon Sel-Way, Inc. v. Spence Bros., Inc. · filed 1989-05-15

MCL 600.6013; MSA 27A.6013 allows interest only on money judgments recovered in civil actions; it does not authorize interest on an arbitration award and the judgments entered confirming the award. The Legislature intended MCL 600.6013; MSA 27A.6013 to apply only to judgments obtained in civil actions, through court proceedings, not arbitration.

Section 600.6013 requires postaward and postjudgment interest, but does not require preaward interest when arbitrators did not award it.

Holloway Construction Co. v. Oakland County Board of County Road Commissioners · filed 1996-03-01(6)

However, consistent with Old Orchard, postaward, prejudgment interest and postjudgment interest under § 6013 are statutorily required.

Section 600.6013 allows interest on a money judgment arising from a civil action, including when the parties agree to arbitrate after the lawsuit begins.

Soulliere v. Berger · filed 2023-04-27(1)

Here, however, defendants do not claim that there was an agreement to arbitrate that existed prior to the initiation of this lawsuit. Rather, as defendants admit, the parties reached an agreement to arbitrate during the course of the circuit court litigation. These circumstances are more analogous to the circumstances that were present in Old Orchard By the Bay Assoc v Hamilton Mut Ins Co, 434 Mich 244; 454 NW2d 73 (1990), disavowed in part on other grounds by Holloway Constr Co v Oakland Co Bd of Co Rd Comm’rs, 450 Mich 608, 615-616 (1996). ... In light of Old Orchard, defendants in this case have not demonstrated that the award of interest under MCL 600.6013 was erroneous.

Section 600.6013 requires interest on a civil money judgment from the date the complaint is filed, including interest attributable to the insurer's portion of the judgment.

Denham v. Bedford · filed 1978-03-20

In accord with Cosby, this Court holds that MCLA 600.6013; MSA 27A.6013 has the effect of becoming a part of the instant contract, thus replacing the clause as' written and mandating that the interest be calculated from the date of filing the complaint.

Section 600.6013 permits prejudgment interest from the complaint date on a judgment entered after an offer of judgment, and the interest may be assessed against an insurer in addition to its policy limits when the judgment reaches those limits.

Singleton v. Davis · filed 1980-01-23

In accordance with the provisions of MCL 600.6013; MSA 27A.6013, the lower court awarded plaintiff prejudgment interest from the date that she filed her complaint. ... In Denham this Court held that an insurer may be held liable for the amount of its policy limits plus prejudgment interest on that amount, where a money judgment equal to or exceeding the policy limits is awarded. The fact that plaintiffs award arose out of an offer of judgment and not a jury verdict does not alter this result. McGrath v Clark, 89 Mich App 194; 280 NW2d 480 (1979).

Section 600.6013 applies to insurance contracts and requires an insurer to pay prejudgment interest on the portion of a judgment within its policy limits, even if that interest exceeds the contractual policy limits.

Denham v. Bedford · filed 1980-02-01

Based upon the intent of the Legislature in enacting the prejudgment interest statute, interpretation of the insurance policy, and common-law and public policy considerations, we hold that an insurer is liable for prejudgment interest on that portion of a judgment representing the policy liability of the insurer.

Section 600.6013 requires interest to be calculated from the date the complaint is filed and provides no special later starting date for comparative-negligence cases.

Bush v. Oscoda Area Schools · filed 1981-09-10

MCL 600.6013; MSA 27A.6013 provides for interest to be calculated from the date of filing the complaint. ... The Legislature could have provided that interest be calculated from February 8, 1979, in cases involving a finding of comparative negligence filed prior to February 8, 1979. It did not.

Section 600.6013 provides prejudgment interest to compensate for delay in payment of money damages, and interest does not accrue before the claimed funds are detained by the defendant.

Foremost Life Insurance v. Waters · filed 1983-05-17

We hold that, under the facts of this case, the trial judge erred in awarding interest from the date of filing the complaint. Defendant was not in possession of the funds to which plaintiff asserted a claim until April 8, 1977. Until that date there had been no detention of funds by defendant. Defendant’s delay in paying plaintiff pursuant to its request under the subrogation clause did not begin until April 8, 1977.

Section 600.6013(1) requires prejudgment interest on a money judgment to accrue from the date the complaint is filed, rather than from a later amended complaint.

Rittenhouse v. Erhart · filed 1986-01-08(1)

Section 6013 plainly says that "interest on the judgment shall be calculated from the date of the filing of the complaint."

Section 600.6013 requires prejudgment interest to be assessed from the date the complaint is filed.

Brunson v. E & L TRANSPORT CO. · filed 1989-05-15

Finally, defendant claims that the award of prejudgment interest from the date plaintiff filed her complaint constituted a penalty which violates due process and equal protection. MCL 600.6013; MSA 27A.6013 is unambiguous and expressly pro-* vides for the assessment of interest from the date of filing the complaint. Defendant’s constitutional challenge to the statute is without merit.

Section 600.6013 requires prejudgment interest from the date of the formal complaint filed against the defendant on whom the interest is taxed, and statutory interest is mandatory.

Phinney v. Perlmutter · filed 1997-06-16(1) (6)

Imposition of statutory interest under this statute is mandatory. ... Prejudgment interest must be paid from the date the complaint is filed. ... Rather, “the complaint” for purposes of this statute is the “formal complaint filed against the defendant upon whom the prejudgment interest is being taxed.” ... Accordingly, prejudgment interest was awardable from the date that a complaint was filed against Perlmutter.

When parties agree to entry of judgment under an offer-of-judgment rule without addressing prejudgment interest, the prevailing party is entitled to interest under § 600.6013.

McGrath v. Clark · filed 1979-03-20

In conclusion, we hold that where the parties agree on the entry of judgment under GCR 519.1, but make no provision for prejudgment interest, the party in whose favor the judgment is entered is entitled to interest under RJA § 6013.

Section 600.6013 provides six-percent judgment interest that may be awarded cumulatively with the no-fault act’s 12-percent penalty interest.

Hartman v. Insurance Co. of North America · filed 1981-06-03

The purpose of the six percent interest statute is to compensate the prevaling party for the expenses incurred in bringing an action and for the delay in receiving money damages. ... The 12 percent interest provision is intended to penalize the recalcitrant insurer rather than compensate the claimant. ... We do not consider these statutes to be mutually exclusive. Therefore, the trial court correctly ordered both the six percent and the 12 percent interest.

Section 600.6013 provides for judgment interest on amounts awarded in a civil judgment.

Hay v. City of Highland Park · filed 1984-05-14

Judgment interest under MCL 600.6013; MSA 27A.6013 should be awarded on the net increase in pension amounts due to plaintiffs.

Section 600.6013 permits recovery of interest on a judgment even when usury law bars interest on the original debt, encouraging prompt compliance with court orders.

Farley v. Fischer · filed 1984-09-18

Plaintiff is, however, entitled to judgment interest at 12% under MCL 600.6013; MSA 27A.6013. The judgment interest statute evidences a legislative intent to encourage prompt compliance with court orders. Absent the imposition of judgment interest, defendant has little incentive to comply with the trial court’s order requiring payment of the principal. The usury statute bar against recovery of interest, on the other hand, discourages the imposition of usurious rates on original debts by disallowing the recovery of the legal rate of interest once a rate has been determined usurious. We see no conflict between these two statutes and conclude that while MCL 438.32; MSA 19.15(2) precludes recovery of interest on the original debt, MCL 600.6013; MSA 27A.6013 allows recovery on the judgment.

Section 600.6013 governs prejudgment interest on money judgments, including when interest begins and when payment into escrow ends accrual on the tendered amount.

Central Michigan University Faculty Ass'n v. Stengren · filed 1985-05-06

We do affirm the trial court’s method of computation of the prejudgment interest to which plaintiff was entitled. MCL 600.6013; MSA 27A.6013 provides for prejudgment interest. In accordance with Foremost Life Ins Co v Waters (On Rem), 125 Mich App 799; 337 NW2d 29 (1983), the trial judge properly limited plaintiff to recovery of prejudgment interest on the service fees payable after the complaint was filed from the date they became due. Plaintiff is not entitled to prejudgment interest on the entire amount of the judgment from the date the complaint was filed. The trial judge also properly limited plaintiff to recovery of the interest earned by the service fees paid into the escrow account. The payment of the service fees into the escrow account cut off plaintiff’s right to prejudgment interest as to the amount tendered into the escrow account.

Section 600.6013 authorizes interest only on a money judgment recovered in a civil action.

Law Offices of Lawrence J Stockler, PC v. Rose · filed 1989-01-03

MCL 600.6013; MSA 27A.6013 allows "interest on a money judgment recovered in a civil action.” The Roses did not recover a money judgment against Touche Ross and, hence, cannot recover statutory interest as an element of damages even under the suit within a suit concept.

Section 600.6013 entitles a prevailing party to prejudgment interest from the filing of the complaint through entry of judgment, including on future damages except those resulting from personal bodily injury.

TUCKER & ASSOCIATES, INC. v. Allied Chucker Co. · filed 1999-06-22

MCL 600.6013; MSA 27A.6013 entitles a prevailing party in a civil action to prejudgment interest from the date of filing the complaint to the entry of the judgment. ... This Court recently held that, except for future damages resulting from a personal bodily injury, a plaintiff is entitled to prejudgment interest on the entire money judgment, including future damages, from the date of the filing of the complaint. ... On the basis of this Court's decision in Paulitch and construing the prejudgment interest statute liberally in favor of plaintiff, we conclude that the trial court did not err in awarding interest on the entire judgment, including that portion of damages that reflected commissions due after the complaint was filed but before entry of judgment, from the date that the original complaint was filed.

Section 600.6013 allows prejudgment interest only when the plaintiff recovers a money judgment, not when the court merely grants declaratory relief for amounts already tendered.

Casey v. Auto-Owners Insurance · filed 2007-03-14

The trial court’s reliance on whether the monies were advanced conditionally or unconditionally is irrelevant given that the statute makes no such distinction. ... However, the judgment is not a money judgment as required by the statute, but rather, as the trial court construed it, “declaratory relief.” Because Auto-Owners had already tendered its policy limits to the Caseys, the trial court’s order resulted in a mere declaration that the Caseys were entitled to the policy amounts already offered by Auto-Owners. Without a money judgment, the Caseys are not entitled to interest. Accordingly, we conclude that the trial court properly denied the Caseys prejudgment interest.

Section 600.6013 requires interest on a money judgment from the date the complaint is filed, but when a settlement is deducted from the verdict, statutory interest does not run on the settled amount.

Silisky v. Midland-Ross Corp. · filed 1980-05-19

MCL 600.6013; MSA 27A.6013 reads: "Interest shall be allowed on any money judgment recovered in a civil action, such interest to be calculated from the date of filing the complaint at the rate of 6% per year unless the judgment is rendered on a written instrument having a higher rate of interest in which case interest shall be computed at the rate specified in the instrument if such rate was legal at the time the instrument was executed.” ... Except for the fact that in Awedian the jury itself, rather than the trial judge, deducted from the damages the amount of the settlement, we find no meaningful difference between it and the instant case. The purpose of awarding interest from the date a complaint is filed until date of satisfaction of judgment is to compensate the prevailing party for the time taken to determine the dollar amount, if any, of the loss. When plaintiff voluntarily settled with the other five defendants, plaintiff traded off the loss of interest for the waiting period in exchange for the certainty of the settlement.

Section 600.6013 does not require statutory prejudgment interest when a civil action is terminated by dismissal following a settlement because no final judgment was rendered.

Quarters v. Michigan Physicians Mutual Liability Co. · filed 1986-09-09

Plaintiffs argument fails in its premise that the prejudgment interest statute, MCL 600.6013, MSA 27A.6013, is applicable on these facts. This Court has twice held that where a case is terminated by dismissal following a settlement the right to statutory prejudgment interest is waived—and, hence, the legal responsibility to pay such interest is removed—because no final judgment was rendered.

Section 600.6013's statutory prejudgment interest is waived for a stay of proceedings when the delay is not caused by the defendant.

Rodriguez v. Solar of Michigan, Inc · filed 1991-10-08

The issue whether a stay tolls the accruing of statutory prejudgment interest, MCL 600.6013; MSA 27A.6013, was discussed in Heyler, supra, pp 151-153. The Heyler Court upheld the lower court’s disallowance of interest during a stay of proceedings while awaiting a relevant Supreme Court decision because the delay was not the fault of, nor was it caused by, the defendant. Similarly, in this case the delay was not the fault of Bosley. Thus, interest should be waived for the period during which the stay was in effect.

Section 600.6013 requires prejudgment interest to be calculated only on the defendant's liability after settlement amounts are subtracted from the total judgment.

Freysinger v. Taylor Supply Co. · filed 1992-12-08

Under MCL 600.6306(1); MSA 27A.6306(1), the judgment amount is calculated to include interest as that interest is permitted under MCL 600.6013; MSA 27A.6013. Then, proceeding to MCL 600.6306(3); MSA 27A.6306(3), the amount of the settlement is subtracted from the total judgment. ... To calculate interest on this amount pursuant to MCL 600.6013; MSA 27A.6013, the $100,000 settlement must be subtracted and the interest calculated upon only defendants’ $50,000 liability. ... The interest, calculated only on the $50,000 liability pursuant to MCL 600.6013; MSA 27A.6013, is then added to the total judgment amount, as required by MCL 600.6306(1); MSA 27A.6306(1). Then, proceeding to MCL 600.6306(3); MSA 27A.6306(3), the $100,000 settlement is subtracted from the total judgment, for a judgment against defendants in the amount of $50,000, plus interest on the $50,000 as calculated under MCL 600.6013; MSA 27A.6013.

Section 600.6013 provides six percent judgment interest to compensate the prevailing party for litigation expenses and delay, and that interest may be awarded alongside the no-fault act's 12 percent penalty interest.

Wood v. Detroit Automobile Inter-Insurance Exchange · filed 1980-08-28

The purpose of the six percent interest statute is to compensate the prevailing party for the expenses incurred in bringing an action and for the delay in receiving money damages. ... The 12 percent interest provision is intended to penalize the recalcitrant insurer rather than compensate the claimant. ... We do not consider these statutes to be mutually exclusive. Therefore, the trial court correctly ordered both the six percent and the 12 percent interest.

Section 600.6013 provides for mandatory statutory interest on a judgment, even when the judgment includes a separate interest provision.

McGraw v. Parsons · filed 1985-04-15

Statutory interest is computed on and added to the judgment. The statutory judgment interest provision is designed to compensate the plaintiff for the loss of use of the funds and is mandatory in nature. ... We conclude that the 6% interest provision in the 1972 consent judgment does not preclude the award of statutory judgment interest under MCL 600.6013; MSA 27A.6013.

Section 600.6013 provides six percent judgment interest to compensate the prevailing party for litigation expenses and delay in receiving money damages, and that interest may be awarded alongside no-fault penalty interest.

Nash v. Detroit Automobile Inter-Insurance Exchange · filed 1982-10-19

The 12 percent interest provision is intended to penalize the recalcitrant insurer rather than compensate the claimant.

Section 600.6013 judgment interest may be awarded together with interest under the no-fault act.

Butler v. Detroit Automobile Inter-Insurance Exchange · filed 1982-12-06

The statute on judgment interest and the interest provision in the no-fault act are not mutually exclusive. Therefore the interest awards were proper.

Section 600.6013 mandates statutory interest from the filing of the complaint through satisfaction of the judgment, and a separate recovery under another contract does not make that interest a windfall.

Shanafelt v. Allstate Insurance · filed 1996-09-13

First, plaintiff is correct that MCL 600.6013; MSA 27A.6013 mandates that statutory interest be awarded ... Thus, plaintiff was wrongfully denied her recovery under the no-fault contract, the type of situation MCL 600.6013; MSA 27A.6013 was meant to address. Whether plaintiff recovered under a second, distinct contract with another legal entity is immaterial. Therefore, the circuit court erred in refusing to award plaintiff statutory interest.

Section 600.6013(8) requires a court to award statutory interest on a money judgment when the statute applies.

Centria Home Rehabilitation LLC v. Allstate Insurance Company · filed 2024-11-18(8)

Although plaintiff did so, the trial court failed to award statutory interest in accordance with MCL 600.6013(8). We therefore reverse in part the trial court’s February 23, 2023 opinion and order to the extent that the trial court denied plaintiff’s request for statutory interest and remand this case to the trial court for an award of statutory interest under MCL 600.6013(8).