The Illinois Appellate Court recently ruled on a case involving prejudgment interest in a negligence lawsuit. The court ordered RK Holdings, also known as Rural King, to pay $3,064.75 in accrued statutory prejudgment interest to Cinthya A. Pedigo. This decision affects how prejudgment interest is applied in personal injury cases in Illinois and clarifies the timeline for such claims.
The dispute began when Pedigo filed a negligence action against RK Holdings after she was injured in their store. The court's ruling emphasizes the importance of statutory provisions regarding prejudgment interest and clarifies the jurisdiction of courts in modifying judgments.
Background
The case, Pedigo v. RK Holdings, LLP, was filed in the Circuit Court of Montgomery County under docket number 5-25-0743. Pedigo alleged that she suffered serious injuries in October 2023 when multiple feed bucket lids fell on her while she was shopping at a Rural King store. A jury trial took place on March 31 and April 1, 2025, resulting in a verdict of $35,000 in damages awarded to Pedigo.
After the jury's verdict, the circuit court entered a judgment on April 1, 2025. Neither party challenged the jury's decision through posttrial motions or appeals. However, on June 13, 2025, Pedigo filed a citation to discover assets, asserting that the total amount owed, including court costs and interest, was $40,268.55. The defendant made a payment of $35,000 plus postjudgment interest shortly before a scheduled hearing.
The Ruling
On August 14, 2025, the circuit court ruled in favor of Pedigo, ordering RK Holdings to pay her the prejudgment interest of $3,064.75. The court determined that the plaintiff was entitled to this interest based on statutory provisions. The court noted, “Pre-judgment interest in this cause is purely statutory and arises automatically after the jury’s judgment verdict was tendered.” The ruling emphasized that the court had the authority to add prejudgment interest to the judgment even though the request was made after the typical 30-day window for postjudgment motions.
The Appellate Court upheld this decision, stating that the plaintiff's request for prejudgment interest did not challenge the original judgment but sought to enforce it. The court found that the request was in line with the statutory provisions and did not fall under the 30-day jurisdictional limit typically applied to posttrial motions.
Impact
This ruling has significant implications for future personal injury cases in Illinois. It clarifies that prejudgment interest can be awarded even if the request is made after the standard time frame for postjudgment motions. The court's interpretation of section 2-1303 of the Illinois Code of Civil Procedure indicates that prejudgment interest is mandatory in personal injury cases and does not require a specific timeframe for requests.
The decision reinforces the idea that prejudgment interest is an automatic addition to judgments in personal injury cases, promoting fair compensation for plaintiffs. This ruling may encourage more plaintiffs to pursue their rights under the statutory provisions for prejudgment interest, knowing that they have the backing of the court.
What's Next
RK Holdings has the option to appeal this decision, but details regarding any potential appeal were not available in the court filing. This case may set a precedent for how courts handle similar requests for prejudgment interest in the future.