Supreme Court of Colorado

Joel Munoz, Petitioner v. American Family Mutual Insurance Company, Respondent.

September 10, 2018425 P.3d 1128

Summary

The court held that an insured may not recover prejudgment interest on a settlement of an uninsured motorist claim. Under the plain language of the prejudgment-interest statute, recovery requires an action, a complaint claiming damages and interest, a finding of damages by a jury or court, and entry of judgment. Because Munoz settled rather than obtaining a judgment, the court affirmed the court of appeals.