Parish Ex Rel. Parish v. Henry

OPALA, V.C.J.,

concurring.

¶ 1 The court today (1) reverses the summary adjudication that favors the plaintiff in a postjudgment garnishment proceeding in which the trial court ruled the medical malpractice insurer to be liable to the plaintiff for the entirety of prejudgment-interest award against the defendant physician, even though the amount of that recovery, when added to the judgment, exceeded the insurer’s policy limits, and (2) remands the proceeding with directions to enter a post-judgment order in favor of the insurer.

¶2 Although I join the court’s opinion without any qualification, I write separately to clarify McDonald’s1 impact on today’s treatment of prejudgment interest as an inseparable component of recovery.

I

THE GENERAL RULE — PREJUDGMENT INTEREST IS AN INSEPARABLE COMPONENT OF RECOVERY

¶ 3 Statutorily authorized prejudgment interest is an item of recovery that constitutes an integral part of the judgment debtor’s total adjudged liability.2 It stands in the law as an item of damages owed for the delayed satisfaction of an obligation on which it accrues.3 Because prejudgment interest, which represents here an amount in excess of the insurer’s liability limits, is an inseparable part and parcel of recovery, I concur in the court’s pronouncement that the insurer cannot be made accountable for its satisfaction.

*651II

THE MCDONALD EXCEPTION TO THE GENERAL RULE

¶4 McDonald is consistent with today’s pronouncement. It teaches that prejudgment interest may be regarded as a “claim expense” (within the terms of a policy) when the insurer, who controls the investigation, defense and appeal of a lawsuit, delays the lawsuit’s termination by vacillating between going forward and paying the loss and attempting to defeat liability.4 In McDonald the certified facts submitted to this court unequivocally supported our treatment of prejudgment interest as a claim expense.5 In short, McDonald is to be viewed as an exception to the general rule. It was there warranted by the undenied facts about the insurer’s trial-strategy choices.

III

THIS CASE PRESENTS FACTS UNEQUIVOCALLY WARRANTING THE COURT’S APPLICATION OF THE GENERAL RULE.

¶ 5 Unlike in McDonald, the liability for prejudgment interest is in this case utterly unclouded by adverse actions of the insurer as dominus litis.6 By the explicit terms of the policy, the insured, who had the right to disapprove any settlement offer, was twice extended an opportunity to settle the controversy for the liability limits of the policy — the first of these occurred one year before the trial and the second at mid-trial. Because the defendant refused both offers, prejudgment interest in excess of the policy limits must fall on him as the insured.

We have the right and will defend any claim.
We will:
1.do this even if any of the charges of the claim are groundless, false, or fraudulent;
2. investigate any claim as we feel appropriate
3. not settle any claim without your consent. Supra note 1, at ¶ 9, at 578.

. See McDonald v. Schreiner, 2001 OK 58, 28 P.3d 574, where the court answered a question of state law certified to it by the federal court.

. McDonald, supra note 1 at ¶ 7, at 577.

. "Prejudgment interest obligation is (a) a consequence of delay caused by the decision to defend against the claim, (b) constitutes an expense incident to the chosen course of litigation, and (c) presents a recovery component that stems directly from the insurer-adopted set of forensic strategy choices. All of the litigation-attendant expenses are within the direct and exclusive control of the insurer. The latter party investigates the claim and chooses whether to settle or defend it. Delay is a product of the insurer's will and conduct The longer the delay, the more prejudgment interest accrues. Without an obligation for that interest insurers would be provided with incentive to prolong litigation in order to take advantage of the time value of money still in their hands.” McDonald, supra note 1, at ¶ 8, at 577-78 (footnotes omitted).

. McDonald, supra note 1, at W 7-8, at 577-78.

. The insurance policy’s terms in McDonald reveal the presence of" insurer’s absolute control over the course of the litigation. The McDonald policy stated in pertinent part:

. Literally translated, dominus litis means master of the suit, i.e., one who by law is entitled to manage and control the litigation to the exclusion of others. Black's Law Dictionary 437 (5th ed.1979).