Arcadia Farms Partnership v. Audubon Insurance Company, 77 So.3d 100 (Miss. Sup. Ct. 2012)

(plaintiff’s cotton picking machine destroyed by fire; defendant ultimately paid $100,000 on insurance claim for plaintiff’s loss, but plaintiff claimed that payment not made in timely manner as required by policy and constituted a “bad faith breach of the policy terms”; plaintiff sued for punitive damages; defendant claimed that under state (MS) law plaintiff’s only claim compensatory damages would be for pre-judgment interest, but such interest was barred before filing the complaint and it had not been requested in the complaint and, in turn, without compensatory damages, punitive damages could not be recovered; trial court granted summary judgment for defendant, but appellate court reversed; on further review by state Supreme Court, court held that plaintiff could seek pre-judgment interest from date of breach, before complaint filed and that, in contract cases, state law does not limit pre-judgment interest to post-complaint period).