Rhode Island General Laws

R.I. Gen. Laws § 37-6-23 (2026)

Calculation of interest and payment of judgment

✓ current as of July 2026

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(a) If a petition for assessment of damages is filed, then the property owner shall be entitled to interest on the fair market value of the property taken by the acquiring authority from the date it is condemned to the day that judgment enters. Interest thereon shall be calculated on the fair market value of the property which exceeds the amount offered by the acquiring authority pending final disposition of the court proceedings. Upon a recovery of final judgment, an execution shall be issued therefor and shall be forthwith paid by the general treasurer out of any funds appropriated and available therefor. Interest on any judgment shall be computed daily to the date of payment and shall be compounded annually. Interest shall be calculated as follows:

(1) Where the period for which interest is owed does not exceed one year, interest shall be calculated for such period form the date of taking at an annual rate equal to the weekly average one year constant maturity Treasury yield, as published by the Board of Governors of the Federal Reserve System, for the calendar week preceding the date of the taking.

(2) Where the period for which interest is owed is more than one year, interest for the first year shall be calculated in accordance with subdivision (1) of this section and interest for each additional year shall be calculated on the combined amount of the principal and accrued interest at an annual rate equal to the weekly average one year constant maturity Treasury yield, as published by the Board of Governors of the Federal Reserve System, for the calendar week preceding the beginning of each additional year.

(b) In the event the one year constant maturity Treasury yield is converted to a different standard reference base or otherwise revised, the determination of interest shall be made with the use of such converted or revised standard reference base. In the event the Board of Governors of the Federal Reserve System ceases to publish a converted or revised rate, interest shall be calculated at a rate published by the United States Treasury Department, or other comparable entity, that establishes a rate reflecting or best approximating the market conditions for one year investments at the time of the taking and each additional year that interest is owed pursuant to subdivision (2) above.

Notes of Decisions

Cited in 7 cases, 1964–2001 · leading case: Ankner v. Napolitano, 764 A.2d 712 (R.I. 2001).

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Ankner v. Napolitano, 764 A.2d 712 (R.I. 2001). · cites it 12× “This amount represented the city's 50 percent share of the total condemnation proceeds awarded to CPI in 1997, and it included interest calculated at the variable treasury-bill rate specified in G.L. 1956 §§ 37-6-23 and 37-6-29. With respect to the other half of the award, CPI…”

Murphy v. Dir. of Pub. Works, 238 A.2d 621 (R.I. 1968). · cites it 7× “1956, §37-6-23, as amended, upon which defendant relied.”

Bogosian v. Woloohojian, 158 F.3d 1 (1st Cir. 1998). “See R.I. Gen. Laws § 37-6-23. Rhode Island courts consider prejudgment interest statutes to be statutes in derogation of the common law, and construe them strictly.”

M. S. Alper & Son, Inc. v. Dir. of Pub. Works, 200 A.2d 583 (R.I. 1964). · cites it 4× “1956, §37-6-23, which read as follows: “Upon recovery of final judgment, execution shall be issued therefor and shall be forthwith paid by the general treasurer out of any funds appropriated and available therefor, but the verdict and the judgment entered thereon shall not…”

Chartier Real Est. Co. v. Chafee, 225 A.2d 766 (R.I. 1967). · cites it 2× “Section 37-6-23 .provides a remedy for the- enforcement by execution of any final judgment which may be recovered.”

Lischio v. Gill, 704 A.2d 216 (R.I. 1997). · cites it 4× “Because *217 final judgment in this case was entered December 15, 1995, over five months after the July 11,1994 enactment date, the trial justice correctly applied the statute.”

Ocean Road Partners v. State, 670 A.2d 246 (R.I. 1996). “Although § 37-6-23 requires the state to satisfy judgments in condemnation proceedings, there is no analogous provision requiring a landowner who has been overpaid to return the excess payment.”

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