Mich. Comp. Laws » Michigan Compiled Laws / Chapter 438 / R.S. of 1846
Michigan Compiled Laws

Mich. Comp. Laws § 438.7 (2026)

Interest on verdicts.

✓ current as of July 2026
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Revised Statutes of 1846


R.S. of 1846


438.7 Interest on verdicts.

    In all actions founded on contracts express or implied, whenever in the execution thereof any amount in money shall be liquidated or ascertained in favor of either party, by verdict, report of referees, award of arbitrators, or by assessment made by the clerk of the court, or by any other mode of assessment according to law, it shall be lawful, unless such verdict, report, award, or assessment shall be set aside, to allow and receive interest upon such amount so ascertained or liquidated, until payment thereof or until judgment shall be thereupon rendered; and in making up and recording such judgment, the interest on such amount shall be added thereto, and included in the judgment.

History: R.S. 1846, Ch. 34 ;-- CL 1857, 1318 ;-- CL 1871, 1636 ;-- How. 1598 ;-- CL 1897, 4866 ;-- CL 1915, 5996 ;-- CL 1929, 9238 ;-- CL 1948, 438.7

Notes of Decisions
Cited in 36 cases (2 in the last 5 years), 1960–2025 · leading case: Gordon Sel-Way, Inc. v. Spence Bros., 475 N.W.2d 704 (Mich. 1991).
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Gordon Sel-Way, Inc. v. Spence Bros., 475 N.W.2d 704 (Mich. 1991). · cites it 52× “It also granted pre- and post-judgment interest under MCL 438.7; MSA 19.4 at the rate of five percent per annum from the date of the arbitration award until the date the judgment was satisfied.”
Old Orchard by the Bay Assocs. v. Hamilton Mut. Ins., 454 N.W.2d 73 (Mich. 1990). · cites it 78× “Subsequently, defendant Hamilton Mutual filed several motions, including a claim that the arbitrators erred in awarding interest other than that allowable under the prejudgment interest statute, MCL 438.7; MSA 19.4, from the date of the arbitration award.”
City of Detroit v. Detroit Police Officers Ass'n, 294 N.W.2d 68 (Mich. 1980). · cites it 12× “Since Act 312 itself is silent on the subject of interest, the DPOA and the DFFA base their appeal on MCL 438.7; MSA 19.4, as well as MCL 600.6013; MSA 27A.”
People v. Stephan, 616 N.W.2d 188 (Mich. Ct. App. 2000). · cites it 10× “Given the manner of their enactment and the similar functions that the two statutes have performed for more than a century, the amendment of M.”
Holloway Constr. Co. v. Oakland Cnty. Bd. of Cnty. Road Commissioners, 543 N.W.2d 923 (Mich. 1996). · cites it 5× “6013 3 and MCL 438.7; *613 MSA 19.4. 4 Our decisions in Old Orchard and Gordon Sel-Way, Inc v Spence Bros, Inc, 438 Mich 488 ; 475 NW2d 704 (1991), are relevant to the issue before us.”
Manley, Bennett, McDonald & Co. v. St. Paul Fire & Marine Ins., 821 F. Supp. 1225 (E.D. Mich. 1993). · cites it 15× “§ 438.7 and M.C.L. § 438.31, and argues that these statutes limit pre-complaint interest to 5% simple interest per year.”
Wilson v. Doehler-Jarvis Div. of Nat'l Lead Co., 100 N.W.2d 226 (Mich. 1960). · cites it 4× “Moreover such would result in a situation never contemplated nor intended by the workmen's compensation law and which would be repugnant to its basic purposes.”
Holland v. Earl G. Graves Pub. Co., Inc., 33 F. Supp. 2d 581 (E.D. Mich. 1998). · cites it 5× “However, Michigan Compiled Laws Section 438.7 governs the award of interest, and provides, in pertinent part, as follows: [i]n all actions founded on contracts express or implied, whenever .”
Osinski v. Detroit Auto. Inter-Ins. Exch., 245 N.W.2d 76 (Mich. Ct. App. 1976). · cites it 5× “Although the trial court erred in applying §6013, we think MCLA 438.7; MSA 19.4, authorizes the interest awarded herein.”
Jones v. Jackson Nat'l Life Ins., 819 F. Supp. 1382 (W.D. Mich. 1993). · cites it 5× “7, whenever “any amount in money shall be liquidated or ascertained in favor of either party, by verdict, report of referees, award of arbitrators, or by assessment made by the clerk of the court, or by any other mode of assessment according to law.”
Moultrie v. Detroit Auto. Inter-Ins. Exch., 333 N.W.2d 298 (Mich. Ct. App. 1983). · cites it 4× “In the instant case the arbitration proceedings were instituted by a filing of a claim for arbitration with the insurance company — not a complaint with the court. The pre-circuit court proceedings simply were not the equivalent of civil action, and therefore § 6013 does not…”
Morgan v. Kamil, 375 N.W.2d 378 (Mich. Ct. App. 1985). · cites it 4× “The panels of this Court deciding these cases have all held that interest on the arbitration award is based on MCL 438.7; MSA 19.4, not on MCL 600.6013; MSA 27A.”
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