Section 4.21 Interest

• Library: Contracts 2016 Supp

E. (§4.21) Interest

Missouri follows the general rule allowing prejudgment interest on a contract claim when the amount is liquidated or is capable of ascertainment. Burger v. Wood, 446 S.W.2d 436 (Mo. App. S.D. 1969). In these cases, the interest is measured from the time of the breach. Prudential Ins. Co. of Am. v. Goldsmith, 192 S.W.2d 1 (Mo. App. W.D. 1945). But prejudgment interest will not be awarded on a judgment for lost profits. Scullin Steel Co. v. PACCAR, Inc., 708 S.W.2d 756 (Mo. App. E.D. 1986).

The material supplier’s lien statute expressly authorizes prejudgment interest. Section 429.210, RSMo 2000. A dispute as to liability does not make an amount unliquidated...