Catlin Insurance Company, Inc. v. Danko
- Haywood Gilliam
- 4:20-cv-01345
- U.S. District Court · Northern District of California
- 3
Catlin Insurance Company, Inc. v. Danko Meredith: Judge Gilliam denied Catlin’s request to add pre- and post-judgment interest to the $180,000 judgment.
Catlin Insurance Company, Inc.’s request to add pre- and post-judgment interest was denied; the order did not add interest to the $180,000 judgment.
What happened
Catlin Insurance Company, Inc. v. Danko Meredith arose from Catlin’s duplicate $180,000 settlement payment to Danko Meredith’s client trust account and by check. The court had entered judgment for $180,000 after Catlin said it sought only return of the duplicate payment.
Catlin later asked to amend the judgment to add pre- and post-judgment interest. The court denied the request because Catlin had not shown newly discovered evidence, clear error, a change in the law, or extraordinary circumstances, and because its request came after its earlier representations.
Judge Haywood S. Gilliam, Jr. denied Catlin’s motion to amend the judgment.
The detailed version
- Catlin Insurance Company, Inc. v. Danko · No. 4:20-cv-01345
- Haywood Gilliam
- May 20, 2022
Background
Catlin Insurance Company, Inc. sued to recover a duplicate settlement payment made in connection with an underlying California state-court wrongful-death lawsuit. After a plane crash in July 2012, Danko Meredith represented the heirs of one decedent, Michael Boolen. Catlin sent $180,000 to Danko Meredith’s client trust account and, two days later, mistakenly sent another $180,000 by check. Danko Meredith acknowledged receiving the duplicate payment but refused to return the funds.
During the hearing on Catlin’s summary-judgment motion, the court asked whether Catlin sought anything beyond return of the duplicate $180,000 payment. Although Catlin’s complaint had requested compensatory damages, interest, attorney’s fees, and costs, Catlin’s counsel confirmed that nothing further was required after the summary-judgment order and that Catlin was not seeking additional damages. Relying on those representations, the court entered judgment for Catlin in the total amount of $180,000.
Motion and ruling
Catlin later moved under Federal Rule of Civil Procedure 59(e) to amend the judgment to include prejudgment and post-judgment interest. The court explained that Rule 59(e) motions may be granted only in limited circumstances, including newly discovered evidence, clear error, a change in the law, or other extraordinary circumstances.
The court found that Catlin had identified none of those grounds. It particularly noted Catlin’s earlier representations that it sought only return of the duplicate payment. The court therefore denied the motion to amend the judgment.
Effect of the order
The order denied Catlin’s request to add pre- or post-judgment interest. It did not alter the court’s stated $180,000 judgment in this ruling. Judge Haywood S. Gilliam, Jr. signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.