Michigan Compiled Laws

Mich. Comp. Laws § 213.65 (2026)

Interest on judgment amount.

✓ current as of July 2026
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THE UNIFORM CONDEMNATION PROCEDURES ACT


Act 87 of 1980


213.65 Interest on judgment amount.

Sec. 15.

    (1) The court shall award interest on the judgment amount or part of the amount from the date of the filing of the complaint to the date that payment of the amount or part of the amount is tendered. However, if a portion of the judgment is attributable to damages incurred after the date of surrender of possession, the court shall award interest on that portion of the judgment from the date the damage is incurred.

    (2) Interest shall be computed at the interest rate applicable to a federal income tax deficiency or penalty. However, an owner remaining in possession after the date that the complaint is filed waives the interest for the period of the possession.

    (3) If it is determined that a de facto acquisition occurred at a date earlier than the date of filing the complaint, interest awarded under this section shall be calculated from the earlier date.

History: 1980, Act 87, Imd. Eff. Apr. 8, 1980 ;-- Am. 1996, Act 474, Imd. Eff. Dec. 26, 1996

Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1984–2025 · leading case: Lenawee Cnty. v. Wagley, 836 N.W.2d 193 (Mich. Ct. App. 2013).
Lenawee Cnty. v. Wagley, 836 N.W.2d 193 (Mich. Ct. App. 2013). · cites it 10× “Disagreements pertaining to an expert witness’s interpretation of the facts are relevant to the weight of that testimony and not its admissibility.”
Escanaba & Land Superior R.R. Co. v. Keweenaw Land Ass'n, 402 N.W.2d 505 (Mich. Ct. App. 1986). · cites it 3× “Plaintiff claims on appeal that the interest provision of the Uniform Condemnation Procedures Act, MCL 213.65; MSA 8.265(15), applies. Defendants claim that the interest statute applicable to all civil actions, MCL 600.”
City of Detroit v. J Cusmano & Son, Inc, 459 N.W.2d 3 (Mich. Ct. App. 1989). · cites it 2× “Section 15 of the ucpa, MCL 213.65; MSA 8.265(15), provides for payment of interest on the judgment as follows: The court shall award interest on the judgment amount from the date of the filing of the complaint to the date of payment of the amount, or any part of the amount.”
Wayne Cnty. v. Britton Trust, 563 N.W.2d 674 (Mich. 1997). “MCL 213.65; MSA 8.265(15) (interest on judgment); MCL 213.”
Hartland Twp. v. Kucykowicz, 474 N.W.2d 306 (Mich. Ct. App. 1991). “On September 6, 1988, defendant filed a motion for attorney fees, witness fees, expenses, and interest on the judgment pursuant to MCL 213.65; MSA 8.265(15) and MCL 213.66; MSA 8.”
City of Flint v. Patel, 497 N.W.2d 542 (Mich. Ct. App. 1993). “9 MCL 213.65; MSA 8.265(15). 10 MCL 213.66(3); MSA 8.”
Dep't of Transp. v. Jorissen, 379 N.W.2d 424 (Mich. Ct. App. 1985). · cites it 3× “If it is determined that a de facto acquisition occurred at a date earlier than the date of filing, interest awarded pursuant to this section shall be calculated from the earlier date.”
Dep't of Transp. v. Pichalski, 425 N.W.2d 145 (Mich. Ct. App. 1988). · cites it 2× “MCL 213.65; MSA 8.265(15) provides: The court shall award interest on the judgment amount from the date of the filing of the complaint to the date of payment of the amount, or any part of the amount.”
Dep't of Transp. v. DiMatteo, 355 N.W.2d 622 (Mich. Ct. App. 1984). “” MCL 213.65; MSA 8.265(15) provides in part that: "Sec.”
Dep't of Transp. v. Joslyn Land Co., 438 N.W.2d 260 (Mich. Ct. App. 1988). · cites it 2× “[MCL 213.65; MSA 8.265(15).] Defendants argue that this language requires that the interest should be computed according to the method provided by the Internal Revenue Code, which requires that "such interest and such amount shall be compounded daily.”
Jamestown Shores, LLC v. Jamestown Charter Twp. (W.D. Mich. 2025). · cites it 3× “The Court finds this interest rate will properly compensate JS, as it establishes just compensation for the value of property and applies to the date the property was taken. Id. §§ 213.52, 213.65(3). Additionally, the interest rate applicable to federal income tax deficiencies…”
Dep't of Transp. v. Schultz, 506 N.W.2d 904 (Mich. Ct. App. 1993). “In awarding interest on the appraisal fee, the circuit court relied upon § 15 of the act, MCL 213.65; MSA 8.265(15), which provides: The court shall award interest on the judgment amount from the date of the filing of the complaint to the date of payment of the amount, or any…”
— Mich. Comp. Laws § 213.65(1) — 1 case
Lenawee Cnty. v. Wagley, 836 N.W.2d 193 (Mich. Ct. App. 2013). “Disagreements pertaining to an expert witness’s interpretation of the facts are relevant to the weight of that testimony and not its admissibility.”
— Mich. Comp. Laws § 213.65(6) — 1 case
Consumers Energy Co. v. Brian Storm (Mich. Ct. App. 2020).
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