Donna Yeager v. Maria Alvarez

Summary

The court held that a trial court has authority to strike an offer of compromise as a discovery sanction before deciding whether statutory interest is owed. It nevertheless concluded that striking the offer in this case was an abuse of discretion because the nondisclosure was not intentional, the defendants failed to show significant prejudice, and the sanction was disproportionate. The court reversed the rulings striking the offer and denying interest, directed the trial court to grant the plaintiff's motion for interest, and affirmed the judgment in all other respects.