When Does Postjudgment Interest Start To Accrue?

When an appellate court's remand results in multiple trial court judgments, which of the judgments starts postjudgment interest accrual? The Texas Supreme Court faced that question in Ventling v. Johnson, 58 Tex. S.Ct. J. 892 (Tex. May 8, 2015).

Ventling was a long-running (18 years, not including its duration in the Supreme Court) dispute over an agreed divorce decree. The case began with an April 1995 agreed divorce degree calling for certain periodic payments to the wife. When the husband stopped paying, the wife sued to enforce the decree.

The timeline looked like this:

• April 1995.  Divorce decree entered terminating common-law marriage and dividing property. Two months later the husband stops paying and the wife sues.