Amended Judgments Do Not Reset Post‑Judgment Interest: Interest Runs from the Entry Date of the Unreversed Money Award

1. Introduction

In SNAP! MOBILE v. VERTICAL RAISE (Idaho Supreme Court, Sept. 11, 2026), the Court addressed a recurring post-appeal question: when multiple judgments (original, amended, and post-remand amended) exist in the same case, does post-judgment interest begin anew from the latest judgment date, or does it accrue from earlier entry dates for amounts that were already fixed and not reversed?

The parties were Snap! Mobile, Inc. (“Snap”), the judgment creditor, and Vertical Raise, LLC and Paul Landers (collectively “Vertical Raise”), the judgment debtors. The dispute arose after the first appeal, Snap! Mobile, Inc. v. Vertical Raise, LLC (Snap I), in which the Supreme Court: (i) affirmed discretionary costs, (ii) reversed an additur/new-trial order, and (iii) directed entry of judgment consistent with the jury’s original verdict.

After remittitur, Vertical Raise’s surety paid principal and costs but not post-judgment interest. The district court held that interest accrued from (a) the Original Judgment date for the damages amount stated there, and (b) the Amended Judgment date for costs awarded there, and entered a compliant “Third Amended Judgment.” Vertical Raise appealed, arguing interest could only accrue from the post-remand judgment because earlier judgments were “superseded” and allegedly unenforceable.

2. Summary of the Opinion

The Idaho Supreme Court affirmed. It held that Idaho Code section 28-22-104(2) applies to “all judgments” and does not restrict interest accrual to a single, final, appealable judgment. Where an amount is reduced to a money judgment and is not reversed, post-judgment interest runs from the entry date of that judgment even if later amended judgments are entered. The Court rejected the idea that an amended judgment automatically nullifies the original for interest-accrual purposes. It also awarded Snap attorney fees on appeal under Idaho Code section 12-121, finding the appeal was pursued unreasonably and without foundation.

The Court declined to address disputes over the calculation of post-judgment interest (including whether payment of principal without interest stops further accrual), because that issue was not properly raised or supported on appeal.

3. Analysis

3.1. Precedents Cited

A. Foundational principles: post-judgment interest is statutory

  • Roesch v. Klemann (quoting Chenoweth v. Sanger): the Court reaffirmed that post-judgment interest in Idaho is a “statutory creation,” and that once a debt is reduced to judgment, the statutory rate governs. This framing mattered because Vertical Raise’s argument depended on importing procedural finality concepts into the interest statute.

B. Statutory interpretation methodology

  • Hayden Lake Fire Prot. Dist. v. Alcorn and Stonebrook Constr., LLC v. Chase Home Fin., LLC: the Court reiterated the “plain language” approach—if the statute is unambiguous, it is applied as written.
  • Valentine v. Valentine (citing E. Idaho Econ. Dev. Council v. Lockwood Packaging Corp. Idaho): interpretation of court rules is reviewed freely. This supported the Court’s independent assessment of I.R.C.P. 54(a).

C. Multiple-judgment accrual and “unreversed award” rule

  • Hepworth v. Hepworth: relied on for the proposition that Idaho Code section 28-22-104(2) “does not limit ‘the judgment’ to a single judgment in a proceeding,” leaving room for multiple judgments in one case to carry interest from their respective entry dates.
  • Mitchell v. Flandro (Mitchell II): costs not reversed on appeal earn post-judgment interest from the original judgment date. The Court used this to anchor interest on the cost award from the Amended Judgment date (because costs were fixed there and affirmed in Snap I).
  • Leliefeld v. Panorama Contractors, Inc. (Leliefeld II) and Long v. Hendricks (Long III): damages (or liquidated components) not reversed accrue interest from the original judgment date, even where later supplemental/post-remand judgments are entered.
  • Sanchez v. Galey (Sanchez II) (quoting Dursteler v. Dursteler): where a judgment is modified downward, the final sum draws interest from the date of the original judgment; the Court “perceive[d] no difference between a modification made at the trial court level, or by an appellate court.” The Court treated this as directly undermining Vertical Raise’s “superseded judgment” theory, and it used Sanchez II to explain when a judgment would truly be vacated (e.g., refusal of remittitur/additur triggering a new trial).
  • Sanchez v. Galey (Sanchez I): cited in the narrative of Sanchez II to illustrate that even after appellate activity and remand, interest consequences turn on whether the earlier judgment was actually vacated/reversed and whether tender was made.

D. Stare decisis and attempted escape via rule amendments

  • Thompson v. Burley Inn, Inc. (quoting Gomez v. Crookham Co., with note to Fulfer v. Sorrento Lactalis, Inc.): the Court emphasized stare decisis and the limited grounds for abandoning precedent. This was deployed to reject Vertical Raise’s attempt to argue that the 2010 amendments to I.R.C.P. 54(a) silently displaced Mitchell II, Leliefeld II, and Sanchez II.

E. Appellate briefing limits and issue preservation

  • State v. Ingraham: arguments must be developed with authority in the opening brief; late-raised theories generally are not considered. This was used to discount the “2010 Rule 54(a) amendment changed everything” theory because it was not properly developed initially.
  • Siercke v. Siercke and Dickenson v. Benewah Cnty. Sheriff: the Court will not consider issues raised for the first time on appeal or unsupported by authority—supporting its refusal to opine on interest calculation.
  • Hood v. Poorman (quoting N. Idaho Bldg. Contractors Ass'n v. City of Hayden): “guidance on remand” is appropriate only when the Court reverses/vacates and remands on issues properly raised; here, the Court affirmed and did not remand.

F. Attorney fees on appeal

  • Mortensen v. Berian: explains when Idaho Code section 12-121 fees are appropriate—e.g., where the appellant fails to show incorrect application of well-established law. The Court found Vertical Raise’s appeal met this standard.

3.2. Legal Reasoning

A. Statute governs; “all judgments” means what it says

The Court’s analysis began with the text of Idaho Code section 28-22-104(2): interest applies to money due “on the judgment” and the provision applies to “all judgments.” Relying on Roesch v. Klemann and Hepworth v. Hepworth, the Court treated this as incompatible with Vertical Raise’s attempt to limit accrual to a single, final, appealable judgment.

B. Rule 54(a) defines the form of a judgment; it does not rewrite the interest statute

Vertical Raise argued that because I.R.C.P. 54(a) requires an amended judgment to include “all of the terms” that remain in effect, the amended judgment “supersedes” the original such that the original cannot serve as a basis for interest. The Court rejected this for several reasons:

  • Neither I.R.C.P. 54(a) nor Idaho Code section 28-22-104(2) says interest accrues only on a judgment that is final and appealable.
  • A categorical “amended judgment nullifies original judgment” theory would create serious collateral problems (the Court mentioned priority-rights concerns).
  • Longstanding Idaho precedent holds that if an award is not reversed, interest runs from the date the award was first reduced to judgment, even if subsequent modifications or supplemental judgments occur.

C. Reversal of an additur order is not necessarily reversal of the entire judgment for interest purposes

Vertical Raise contended the Court “operatively reversed” the Amended Judgment in Snap I. The Court disagreed, explaining that Snap I reversed the order granting an additur/new trial but did not reverse the underlying money judgment portions that remained valid (and indeed affirmed costs). At most, Snap I partially reversed the additur component. Under Mitchell II and Leliefeld II, interest continues to accrue on the portions not reversed.

D. Application to the two accrual dates

  • Damages: interest on the $800,000 in the Original Judgment accrues from October 15, 2021 (the Original Judgment entry date). The Court treated the later upward correction in Snap I as irrelevant to whether interest ran on the already-judged $800,000 (and emphasized the district court did not award interest on the additional $200,000 for the earlier period).
  • Costs: because discretionary costs were awarded in the Amended Judgment and affirmed in Snap I, interest accrues from December 14, 2021 (the Amended Judgment entry date), consistent with Mitchell II.

E. 2010 Rule 54(a) amendments did not displace the interest precedents

The Court declined to accept that the 2010 amendments—intended to reduce confusion about final appealable judgments—undermined the interest-accrual cases. It also faulted the argument as not properly developed in the opening brief (State v. Ingraham). Most importantly, the Court reasoned that because interest is statutory and applies to “all judgments,” a procedural rule revision about finality/appealability did not supply a basis to discard Mitchell II, Leliefeld II, or Sanchez II.

3.3. Impact

The decision strengthens (and modernizes in the I.R.C.P. 54(a) era) a clear Idaho rule: amended or post-remand judgments do not automatically reset post-judgment interest accrual dates for amounts already reduced to judgment and not reversed. Practically:

  • Judgment creditors can rely on interest accruing from the earliest operative judgment entry date for unreversed sums, even through complicated post-trial motions and appeals.
  • Judgment debtors and sureties face increased incentive to evaluate tender/partial satisfaction strategies during appellate proceedings, because simply waiting for the “final” post-remand judgment may not avoid interest accrual on amounts already fixed.
  • Trial courts receive firm guidance that multiple judgments in one case can generate interest from different entry dates (e.g., damages versus later-entered costs/fees), consistent with the text of Idaho Code section 28-22-104(2).
  • Appellate practice is affected by the Court’s fee award under Idaho Code section 12-121: appeals that ignore entrenched interest precedent risk being deemed unreasonable and without foundation.

4. Complex Concepts Simplified

  • Post-judgment interest: interest that accrues after a court enters a money judgment, meant to compensate for the time value of money during delay in payment (the Court quoted 47 C.J.S. Interest & Usury § 61).
  • Liquidated amount: a sum that is fixed or readily determinable—once damages or costs are stated in a judgment, they are “reduced to judgment” and statutory interest attaches.
  • Additur: an increase to a jury’s damages award ordered by a trial court (with the defendant’s consent) to avoid a new trial; the opinion referenced McCandless v. Pease for the definition.
  • Remittitur: a reduction in a jury verdict offered as an alternative to a new trial (central in Sanchez v. Galey (Sanchez II)).
  • Remittitur/additur effect on “vacatur” of judgment: under Sanchez II, the original judgment is not “vacated” unless the party refuses the remittitur/additur and the alternative new trial becomes effective.
  • Remittitur (appellate mandate): the appellate court’s formal transmission returning jurisdiction to the trial court after appeal.
  • “Superseded judgment” (as argued here): Vertical Raise used this to mean an amended judgment wipes out the original; the Court rejected that as an interest-accrual rule, emphasizing the statute’s application to “all judgments” and Idaho precedent.
  • Issue preservation: appellate courts generally decide only issues properly raised and supported with authority; the Court relied on Siercke v. Siercke and Dickenson v. Benewah Cnty. Sheriff to decline addressing interest-calculation disputes.

5. Conclusion

SNAP! MOBILE v. VERTICAL RAISE confirms a durable Idaho principle: post-judgment interest under Idaho Code section 28-22-104(2) accrues from the entry date of the judgment that first fixes the relevant monetary obligation, so long as that obligation is not reversed—even if later amended judgments are entered and even if appellate proceedings require post-remand re-entry of judgment.

The decision reinforces that I.R.C.P. 54(a)’s judgment-form requirements and amended-judgment mechanics do not transform the statutory interest rule into a “final-judgment-only” regime. It also signals that attempts to relitigate settled interest-accrual precedent may expose appellants to attorney fees under Idaho Code section 12-121.