Does 2004 Change in Post-Judgment Interest Rate Apply to Judgments Entered Before That Date?
Leonard Maynard v. Eaton Corporation, Case no. 2007-1069 3rd District Court of Appeals (Marion County) ISSUE: Did an amendment to R.C. 1343.03 that took effect on June 2, 2004, adjusting the rate of post-judgment interest payable on unpaid court judgments, apply retroactively to reduce the interest rate payable after June 2, 2004, on judgments that had already been awarded prior to the effective date of the amendment, but in which appeals were still pending on the date the law changed? BACKGROUND: Section 1343.03 of the Ohio Revised Code sets a standard rate of post-judgment interest that is payable to the prevailing party in any civil lawsuit when the non-prevailing party does not make immediate payment of a court-ordered judgment award. Post-judgment interest is typically accrued during a period of time during which the non-prevailing party withholds payment of a judgment while it pursues an appeal of the trial court’s decision. For several years prior to June 2004, the statutory rat
