Neb. Rev. Stat. » Chapter 45
Nebraska Revised Statutes

Neb. Rev. Stat. § 45-103.04 (2026)

Prejudgment interest; exceptions

✓ current as of July 2026
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Interest as provided in section 45-103.02 shall not accrue prior to the date of entry of judgment for:

(1) Any action arising under Chapter 42; or

(2) Any action involving the state, a political subdivision of the state, or any employee of the state or any of its political subdivisions for any negligent or wrongful act or omission accruing within the scope of such employee's office or employment.

Notes of Decisions
Cited in 17 cases (3 in the last 5 years), 1989–2022 · leading case: Weyh v. Gottsch, 303 Neb. 280 (Neb. 2019).
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Weyh v. Gottsch, 303 Neb. 280 (Neb. 2019). · cites it 4× “02 currently provides: (1) Except as provided in section 45-103.04, interest as provided in section 45-103 shall accrue on the unpaid balance of unliquidated claims from the date of the plaintiff's first offer of settlement which is exceeded by the judgment until the entry of…”
Knox v. Cook, 446 N.W.2d 1 (Neb. 1989). · cites it 8× “02 (Reissue 1988) prescribes the conditions for allowance of prejudgment interest on all causes of action accruing on or after January 1, 1987, subject to the exclusions in Neb.Rev. Stat. § 45-103.04 (Reissue 1988), and states: [J]udgment interest shall also accrue on decrees…”
McGill Restoration v. Lion Place Condo. Assn., 309 Neb. 202 (Neb. 2021). · cites it 4× “67 All three of these statutory provi- sions establish different criteria for the recovery of prejudg- ment interest, and none makes the recovery of prejudgment interest contingent on proof of another.”
Cheloha v. Cheloha, 582 N.W.2d 291 (Neb. 1998). · cites it 6× “02 that the trial court applied in the instant case provided the following: Except as provided in section 45-103.04, judgment interest shall also accrue on decrees and judgments for the payment of money from the date of the plaintiff’s first offer of settlement which is exceeded…”
Becher v. Becher, 970 N.W.2d 472 (Neb. 2022). · cites it 4× “Mark’s position that the district court was statutorily pro- hibited from ordering interest to accrue prior to the judgment is based on Neb. Rev. Stat. § 45-103.04 (Reissue 2021).”
Wortman by & Through Wortman v. Unger, 578 N.W.2d 413 (Neb. 1998). · cites it 4× “04, interest as provided in section 45-103 shall accrue on the unpaid balance of unliquidated claims from the date of the plaintiff’s first offer of settlement which is exceeded by the judgment until the rendition of judgment if all of the following conditions are met: (a) The…”
EIKMEIER v. City of Omaha, 783 N.W.2d 795 (Neb. 2010). · cites it 8× “However, this rule is subject to § 45-103.04, which states: Interest as provided in section 45-103.”
Farm & Garden Ctr., L.L.C. v. Kennedy, 26 Neb. Ct. App. 576 (Neb. Ct. App. 2018). · cites it 4× “02, which states, in relevant part: (1) Except as provided in section 45-103.04 [exceptions not applicable here], interest as provided in section 45-103 shall accrue on the unpaid balance of unliquidated claims from the date of the plaintiff's first offer of settlement which is…”
Albee v. Maverick Media, Inc., 474 N.W.2d 238 (Neb. 1991). · cites it 4× “We have held: Neb. Rev. Stat. § 45-103.02 (Reissue 1988) prescribes the conditions for allowance of prejudgment interest on all causes of action accruing on or after January 1, 1987, subject to the exclusions in Neb.”
Wayne L. Ryan Revocable Trust v. Ryan, 308 Neb. 851 (Neb. 2021). · cites it 2× “02(1) provides: Except as provided in section 45-103.04, interest as pro- vided in section 45-103 shall accrue on the unpaid balance of unliquidated claims from the date of the plaintiff’s first offer of settlement which is exceeded by the judgment until the entry of judgment if…”
Ferer v. Aaron Ferer & Sons Co., 725 N.W.2d 168 (Neb. 2006). · cites it 2× “02(2), which provides that “[e]xcept as provided in section 45-103.04, interest as provided in section 45-104 shall accrue on the unpaid balance of liquidated claims from the date the cause of action arose until the entry of judgment.”
Schlake v. Jacobsen, 524 N.W.2d 316 (Neb. 1994). · cites it 2× “02 provides: Except as provided in section 45-103.04, judgment interest shall also accrue on decrees and judgments for the payment of money from the date of the plaintiff’s first offer of settlement which is exceeded by the judgment until the rendition of judgment if all of the…”
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— Neb. Rev. Stat. § 45-103.04(2) — 1 case
EIKMEIER v. City of Omaha, 783 N.W.2d 795 (Neb. 2010). “However, this rule is subject to § 45-103.04, which states: Interest as provided in section 45-103.”
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