Prejudgment Interest

Generally, under Alabama law only liquidated claims justify prejudgment interest. E. C. Ernst, Inc. v. Manhattan Const. Co. of Texas, 551 F.2d 1026, 1042 (5th Cir. 1977) cert. denied Providence Hospital v. Manhattan Const. Co. of Texas, 434 U.S. 1067, 98 S.Ct. 1246, 55 L.Ed.2d 769 (1978) (finding that claims of a general contractor for delays and deficiencies would be to uncertain to qualify for prejudgment interest.). Courts, however, have recognized two exceptions:

U.S. for Use and Ben. of Roper, IBG, a Div. of Roper Corp. v. Reisz, 718 F.2d 1004, 1007-08 (11th Cir. 1983) (applying Alabama law) (finding that contractor was not entitled to prejudgment interest under Alabama law for cost of certain delays caused by subcontractor where the duration of the delay was not certain and where the amount of damages was not ascertainable simply by computation).