ExxonMobil Oil Corporation v. TIG Insurance Company

Background

ExxonMobil Oil Corporation was the petitioner and TIG Insurance Company was the respondent. The judgment addressed the amount owed following a $25 million arbitration award and the date used to calculate interest.

On May 26, 2020, Judge Ramos confirmed the arbitration award and entered judgment for ExxonMobil. The court stated that this was when the judgment became established in a meaningful way and supported by the evidence. The judgment had not been disturbed by the court and had not been set aside after a separate appellate review.

Court’s Analysis

The court reviewed a report and recommendation for clear error, meaning an obvious mistake in the recommended decision. It found no clear error and agreed that May 26, 2020, was the date when prejudgment interest stopped accruing and post-judgment interest began accruing.

The court rejected ExxonMobil’s suggestion that Ninth Circuit authority should guide the analysis instead of decisions from the Second Circuit. It also rejected ExxonMobil’s argument that fairness considerations should affect the date when interest began running, explaining that the Second Circuit had rejected using equitable considerations for that purpose. The court relied on the cited Second Circuit authorities and New York Civil Practice Law and Rules §§ 5002 and 5004.

Disposition

The court adopted the report and recommendation in its entirety as the opinion of the court. Judgment was entered for Mobil in the amount of $26,744,519.50, consisting of the $25 million arbitration award plus prejudgment interest accruing at 9% per year. The opinion identifies Ruby J. Krajick as the Clerk of Court, not as the deciding judge; the deciding judge is therefore stated here as the court.