The Appellate Group

SunStone v. Bodell

SunStone v. Bodell, 2024 UT 9 (Pearce, J.)

Statutory Interpretation

After arbitrating a dispute in Hawaii, SunStone domesticated its Hawaii judgment against Bodell in Utah. Bodell asked the district court to impose Utah’s postjudgment interest rate instead of Hawaii’s higher postjudgment rate, and the district court did just that. SunStone appealed, and the Utah Supreme Court affirmed, holding:

  • The Utah Foreign Judgment Act (UFJA) required the district court to apply Utah’s postjudgment interest rate.
  • The parties’ contract did not require the district court to apply the Hawaii postjudgment interest rate.
  • The court could not use notions of comity to avoid the result the statute requires.
  • Practice tip: The court could envision circumstances where postjudgment interest is specifically awarded in a judgment that a party subsequently domesticates in Utah.
  • Practice tip: The court noted SunStone’s compelling assertion that the UFJA’s purposes could best be promoted through the application of the postjudgment interest rate of the state that renders the judgment, but directed this argument would be best addressed to the Utah Legislature, which could decide to join the list of states that have deviated from the uniform act to mandate that the postjudgment interest rate of the rendering state applies.

Read the full court opinion