fixed standard in Washington

2006Prejudgment interest may be awarded if the judgment is “ Tor an amount due upon a specific contract for the payment of money’ ” and if the amount due is “ ‘determinable by computation with reference to a fixed standard contained in the contract, without reliance on opinion or discretion.' " Kiewit-Grice v. State, 77 Wn.

2006Prejudgment interest may be awarded if the judgment is "`for an amount due upon a specific contract for the payment of money'" and if the amount due is "`determinable by computation with reference to a fixed standard contained in the contract, without reliance on opinion or discretion.'" Kiewit-Grice v. State, 77 Wash. App. 867, 872-73 , 895 P.2d 6 (1995) (quoting CKP, Inc. v. GRS Constr.

2025Prejudgment interest is available “‘(1) when an amount claimed is ‘liquidated’ or (2) when the amount of an ‘unliquidated’ claim is for an amount due upon a specific contract . . . [and] is determinable by computation with reference to a fixed standard contained in the contract.”’ Rekhter v. Dep’t of Soc. & Health Servs., 180 Wn.2d 102, 124 , 323 P.3d 1036 (2014) (quoting Prier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968)).

2025Prejudgment interest is available “when an amount claimed is ‘liquidated’” or “when the amount of an ‘unliquidated’ claim is for an amount due upon a specific contract for the payment of money and the amount due is determinable by computation with reference to a fixed standard contained in the contract, without reliance on opinion or discretion.” Rekhter, 180 Wn.2d at 124 (quoting Prier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968)).

2008Scoccolo Constr., Inc. v. City of Renton, 158 Wn.2d 506, 519 , 145 P.3d 371 (2006). 13 ¶62 Prejudgment interest is available “(1) when an amount claimed is ‘liquidated’ or (2) when the amount of an ‘unliquidated’ claim is for an amount due upon a specific contract for the payment of money and the amount due is determinable by computation with reference to a fixed standard . . . without reliance on opinion or discretion.” Frier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968).

2008Scoccolo Constr., Inc. v. City of Renton, 158 Wash.2d 506, 519 , 145 P.3d 371 (2006). [13] *797 ¶ 62 Prejudgment interest is available "(1) when an amount claimed is `liquidated' or (2) when the amount of an `unliquidated' claim is for an amount due upon a specific contract for the payment of money and the amount due is determinable by computation with reference to a fixed standard ... without reliance on opinion or discretion." Prier v. Refrigeration Eng'g Co., 74 Wash.2d 25, 32 , 442 P.2d 621 (1968).

2008Scoccolo Constr., Inc. v. City of Renton, 158 Wn.2d 506, 519 , 145 P.3d 371 (2006). 13 ¶62 Prejudgment interest is available “(1) when an amount claimed is ‘liquidated’ or (2) when the amount of an ‘unliquidated’ claim is for an amount due upon a specific contract for the payment of money and the amount due is determinable by computation with reference to a fixed standard . . . without reliance on opinion or discretion.” Frier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968).

2008Scoccolo Constr., Inc. v. City of Renton, 158 Wash.2d 506, 519 , 145 P.3d 371 (2006). [13] *797 ¶ 62 Prejudgment interest is available "(1) when an amount claimed is `liquidated' or (2) when the amount of an `unliquidated' claim is for an amount due upon a specific contract for the payment of money and the amount due is determinable by computation with reference to a fixed standard ... without reliance on opinion or discretion." Prier v. Refrigeration Eng'g Co., 74 Wash.2d 25, 32 , 442 P.2d 621 (1968).

2010The interest is awardable “when the amount claimed is liquidated” or “when the amount claimed is unliquidated but is determinable by computation with reference to a fixed standard in a contract.” Id. at 217 .

2010The interest is awardable "when the amount claimed is liquidated," or "when the amount claimed is unliquidated but is determinable by computation with reference to a fixed standard in a contract." Id. at 217 , 70 P.3d 154 .

2004"Such interest is awardable (1) when the amount claimed is liquidated, or (2) when the amount claimed is unliquidated but is determinable by computation with reference to a fixed standard in a contract." Lakes, 117 Wash.App. at 217 , 70 P.3d 154 (citing Prier v. Refrigeration Eng'g Co., 74 Wash.2d 25, 32 , 442 P.2d 621 (1968); Kiewit-Grice, 77 Wash.App. at 872 , 895 P.2d 6 ).

2004“Such interest is awardable (1) when the amount claimed is liquidated, or (2) when the amount claimed is unliquidated but is determinable by computation with reference to a fixed standard in a contract.” Lakes, 117 Wn.

2016Dep 't of Corr. v. Fluor Daniel, Inc., 160 Wn.2d 786, 789 , 161 P.3d 372 (2007); Prier v. Refrigeration Eng'gCo., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968).

2014Fluor, 160 Wn.2d at 789 ; Spradlin, 164 Wn.

2012Polygon Nw., 143 Wn.

2012Polygon Nw., 143 Wash.App. at 790-91 , 189 P.3d 777 .

2010A claim is liquidated if "data in the evidence makes it possible to compute the amount with exactness, without reliance on opinion or discretion." Id. ¶ 21 In Hadley, Division Three awarded prejudgment interest for the period between a damages verdict and an ensuing liability verdict. 120 Wash.App. at 141, 144, 147 , 84 P.3d 286 .

2009Hadley v. Maxwell, 120 Wash.App. 137, 141-42 , 84 P.3d 286 (2004) (quoting Lakes v. Vondermehden, 117 Wash.App. 212, 217 , 70 P.3d 154 (2003)).

2006Co., 63 Wash.App. 601, 614 , 821 P.2d 63 (1991)). ¶ 27 Mothers Work contends the damages here cannot be computed without recourse to opinion or discretion.

2006Co., 63 Wash.App. 601, 614 , 821 P.2d 63 (1991)). ¶ 27 Mothers Work contends the damages here cannot be computed without recourse to opinion or discretion.

1993Hansen v. Rothaus, 107 Wn.2d 468, 472 , 730 P.2d 662 (1986); Seattle v. Dyad Constr., Inc., 17 Wn.

1980Seattle v. Dyad Constr., Inc., 17 Wn.

1972In Blasick v. Yakima, 45 Wn.2d 309 , 274 P.2d 122 (1954), the Supreme Court stated at page 312: We have distinguished the Grass case . . . some six times since 1930, on various phases and circumstances, but we did not give the coup de grace to the idea that negligence in sidewalk cases is a matter of micrometer readings until Johnson v. Ilwaco, (1951), 38 Wn. (2d) 408, 229 P. (2d) 878 , where, speaking of the Grass case, we said (p. 412): “The Grass case must be regarded to a great extent as in a class by itself, and we do not feel that its doctrine should be extended beyond the actual situati

1954We have distinguished the Grass case (in which, incidentally, this court did not have the benefit of a brief from the plaintiff-respondent) some six times since 1930, on various phases and circumstances, but we did not give the coup de grace to the idea that negligence in sidewalk cases is a matter of micrometer readings until Johnson v. Ilwaco (1951), 38 Wn. (2d) 408, 229 P. (2d) 878 , where, speaking of the Grass case, we said (p. 412): “We cannot believe from a reading of the opinion that this court intended to adopt a fixed rule that a city could never be held liable if offsets in sidewalk

2025“Spousal maintenance awards are not governed by a fixed rule but necessarily depend on the facts and circumstances of each case.” Wilcox, 3 Wn.3d at 524 .

2024Dakin, 62 Wn.2d at 691 ; see also RCW 26.09.090(1) (stating that “[t]he maintenance order shall be in such amounts and for such periods of time as the court deems just”).

2020Curb One, Inc. v. City of Renton, 158 Wn.2d 506, 519 , 145 P.3d 371 (2006). 53 Scoccolo Const., 158 Wn.2d at 519 . 54 Prier v. Refrigeration Engineering Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968). 55 Wright v. City of Tacoma, 87 Wn. 334, 353-54 , 151 P. 837 (1915). 26 No. 78543-5-I/27 A claim is liquidated “where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion.”56 A claim is “ ‘unliquidated’ where the exact amount of the sum to be allowed cannot be definitely fixed from the facts proved, . . . but

2020Curb One, Inc. v. City of Renton, 158 Wn.2d 506, 519 , 145 P.3d 371 (2006). 53 Scoccolo Const., 158 Wn.2d at 519 . 54 Prier v. Refrigeration Engineering Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968). 55 Wright v. City of Tacoma, 87 Wn. 334, 353-54 , 151 P. 837 (1915). 26 No. 78543-5-I/27 A claim is liquidated “where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion.”56 A claim is “ ‘unliquidated’ where the exact amount of the sum to be allowed cannot be definitely fixed from the facts proved, . . . but

2019This court has declined "to adopt a fixed rule for delimiting the court's inherent equity power to allocate maintenance costs based on the particular facts and equity of a case." Buck Mountain, 174 Wn.

2017Id. at 703 . 2.

2017Little, 160 Wn.2d at 703-04 .

2016Dep 't of Corr. v. Fluor Daniel, Inc., 160 Wn.2d 786, 789 , 161 P.3d 372 (2007); Prier v. Refrigeration Eng'gCo., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968).

2015App. 688 , 693 n.3, 598 P.2d 407 (1979); Restatement(Second) of Torts § 295A (1965).5 An authoritative Washington evidence treatise warns against the use of a fixed rule to determine admissibility of industry custom or standard in favor of a flexible case- by-case approach: In situations other than products liability actions, generalizations about the relevance of private, nongovernmental standards are hazardous.

2014Fluor, 160 Wn.2d at 789 ; Spradlin, 164 Wn.

2012Polygon Nw., 143 Wash.App. at 790-91 , 189 P.3d 777 .

2004"A claim is liquidated if data in the evidence makes it possible to compute the amount with exactness, without reliance on opinion or discretion." Lakes, 117 Wash. App. at 217 , 70 P.3d 154 (citing Lester N. Johnson Co. v. City of Spokane, 22 Wash. App. 265, 277 , 588 P.2d 1214 (1978)).

2004"A claim is liquidated if data in the evidence makes it possible to compute the amount with exactness, without reliance on opinion or discretion." Lakes, 117 Wash. App. at 217 , 70 P.3d 154 (citing Lester N. Johnson Co. v. City of Spokane, 22 Wash. App. 265, 277 , 588 P.2d 1214 (1978)).

2001A liquidated claim is one whose "exact amount is fixed and known." Prier, 74 Wash.2d at 32 , 442 P.2d 621 . [87] Cement Div., 515 U.S. at 197 , 115 S.Ct. 2091 . [88] City of Milwaukee v. Cement Div., Nat'l Gypsum Co., 515 U.S. 189, 196 , 115 S.Ct. 2091 , 132 L.Ed.2d 148 (1995) (holding neither a good faith dispute over liability nor the existence of mutual fault justifies denying prejudgment interest in an admiralty collision case); see also Thomas J.

2001A liquidated claim is one whose "exact amount is fixed and known." Prier, 74 Wash.2d at 32 , 442 P.2d 621 . [87] Cement Div., 515 U.S. at 197 , 115 S.Ct. 2091 . [88] City of Milwaukee v. Cement Div., Nat'l Gypsum Co., 515 U.S. 189, 196 , 115 S.Ct. 2091 , 132 L.Ed.2d 148 (1995) (holding neither a good faith dispute over liability nor the existence of mutual fault justifies denying prejudgment interest in an admiralty collision case); see also Thomas J.

1993Douglas Northwest, 64 Wn.

1992Styrk v. Cornerstone Invs., Inc., 61 Wn.