Main Practice Contacts

Lynne Liberato
+1 713.547.2017


Nina Cortell
+1 214.651.5579


Karen S. Precella
+1 817.347.6620

Related Services




Judgment Formation and Calculation

Forming a judgment following trial can be a major battle. This battle can add or subtract thousands or millions of dollars to the final judgment, often depending on the calculation of prejudgment interest. Prejudgment interest law in Texas has been described by the Fifth Circuit Court of Appeals as "bewildering" and by the Texas Supreme Court as "all over the map." Haynes and Boone's appellate lawyers are uniquely qualified to assist their clients in obtaining the most favorable judgment possible following trial, including navigating the muddy waters of judgment interest calculation. The seminal case in Texas prejudgment interest law, Johnson & Higgins v. Kenneco, was handled by our appellate lawyers in the Texas Supreme Court. In addition, Haynes and Boone appellate lawyers have spoken and been published on prejudgment interest law and other judgment formation issues more than any other law firm in Texas.

Our lawyers have substantial experience in these and other thorny judgment formation issues that frequently arise, including:


  • Addressing "stacked" damage awards for multiple damage theories and/or multiple damage elements;
  • Application of statutory damage caps;
  • Application of settlement credits;
  • Apportionment of liability;
  • Calculation of additional or treble damages;
  • Awards of attorney's fees;
  • Calculation of post-judgment interest; and
  • Calculation of costs.