Medequa LLC v. O'Neill & Partners LLC

Background

On July 25, 2022, the court granted summary judgment to Medequa. The Clerk entered judgment for Medequa on August 11, 2022. The earlier ruling considered breach of contract and breach of fiduciary duty. Because Medequa had initially moved for partial summary judgment, the parties had not briefed whether Medequa was entitled to interest, and the court did not decide that issue in the summary-judgment ruling.

Medequa then moved under Rule 59(e) of the Federal Rules of Civil Procedure to amend the final judgment to add interest and costs. The court stated that Rule 59(e) allows amendment of a final judgment when the motion is filed within 28 days after entry of judgment and the moving party shows that the court overlooked controlling decisions or data that could reasonably have changed its conclusion. The court also noted that no opposition to Medequa’s motion had been filed.

Court’s Analysis

The court applied New York law. It stated that New York law provides interest at a statutory rate of 9% per year, beginning on the earliest ascertainable date when the claim existed. The court had previously found that O’Neill & Partners breached its contract with Medequa by failing to return escrow funds. The opinion says that the breach occurred on November 23, 2022, the day after Medequa requested return of the funds. It then states that, had the court considered interest in the summary-judgment order, it would have found Medequa entitled to interest beginning November 23, 2020.

Disposition

The court granted Medequa’s motion and amended the judgment to award Medequa LLC $5,100,000, plus costs and interest from November 23, 2020, at a rate of 9% per year. The Clerk was directed to terminate ECF No. 109.

Apparent Date Inconsistency

The opinion identifies the contract breach date as November 23, 2022 but awards interest beginning November 23, 2020. This summary reports both dates as stated in the opinion and does not resolve the apparent inconsistency.