No Award of Prejudgment Interest on Insurance Claim.

The plaintiff's three ag buildings and equipment in the buildings were destroyed by fire.  The buildings were used to dry, process and store hop crops and the equipment was used to store hop bales.  The plaintiff had the buildings and equipment insured under a fire policy issued by the defendant for the cash value of the buildings and equipment, not to exceed the policy limit.  The plaintiff's appraiser determined that the cash value of the buildings and equipment was $1.41 million and the defendant's appraiser severely low-balled the value, pegging it at $380,909.  The defendant paid the $380,909 to the plaintiff.  The defendant hired another appraiser who, expectedly, determined that the plaintiff's appraisal was too high.  The plaintiff sued to recover the balance of what it claimed was owed under the policy, plus prejudgment interest.  The defendant revised its values upwards and paid an additional $85,330.  The matter was submitted to arbitration as the policy required, and the arbitrator set the value at $1.055 million.  The defendant paid an additional $588,761.  The court awarded the plaintiff attorney fees of $82,059.75, but no prejudgment interest.  On appeal, the court affirmed that the plaintiff was not entitled to prejudgment interest because such amount was not due until the amount of loss was ascertained by arbitration.  Jackson Hop, LLC v. Farm Bureau Mutual Insurance Company of Idaho, No. 42384-2014, 2015 Ida. LEXIS 188 (Jul. 16, 2015).