Cinda Haddon v. Ladarius Vanlier et al.

In this case, we determine whether prejudgment interest may be awarded in an action brought against a tortfeasor and defended by an uninsured motorist carrier under Tennessee’s Uninsured Motorist Act. Tenn. Code Ann. §§ 56-7-1201–1206 (2016 & Supp. 2025). The trial court determined that Plaintiff Cinda Haddon could not recover prejudgment interest because her claim was for personal injury. The Court of Appeals reversed, finding that Ms. Haddon brought a contract action. Haddon v. Vanlier, No. M2023-01151-COA-R3-CV, 2024 WL 4590434, at *2–3 (Tenn. Ct. App. Oct. 28, 2024), perm. app. granted, (Tenn. March 17, 2025). Accordingly, the Court of Appeals remanded this matter to the trial court for a determination of prejudgment interest. Id. at *5. Upon review, we find that this is a personal injury action. Because prejudgment interest is not available in a personal injury action, we reverse the Court of Appeals and reinstate the judgment of the trial court denying Ms. Haddon prejudgment interest.