Krasniqi v. A Better Way Wholesale Autos, Inc. et al
ORDER granting 16 Motion for Default Judgment for the reasons set forth in the attached Memorandum of Decision. As stated therein, the Court enters judgment in the amount of $33,007.00, including both actual and punitive damages, as well as post-judgment interest at the rate of 4.75% per annum. The Clerk is directed to close this file. Signed by Judge Vanessa L. Bryant on 6/4/2018. (Hudson, C)
Case 3:18-cv-00058-VLB Document 22 Filed 06/04/18 Page 1 of 2
Sikorsky Fin. Credit Union, Inc. v. Butts, 108 A.3d 228, 232 (Conn. 2015) (noting that
it is within a court’s discretion to determine the rate of post-judgment interest to
award under Section 37-3a). Recently, courts within the District of Connecticut
have awarded interest under Section 37-3a at a rate of 3.5% or 4% per annum, as
consistent with the average bank prime interest rate during the relevant period.
See, e.g., Carney v. Beracha, 3:12-cv-180, 2016 WL 10254460, at *3 (D. Conn. July
22, 2016) (Underhill, J.) (awarding interest under Section 37-3a at a rate of 3.5% as
reflective of “a rough approximation of the average bank prime interest rate during
the relevant period” which extended from 2007 through 2016); Gilmore v. Pawn
King, Inc., 3:08-cv-1058, 2016 WL 1180147, at *11 (D. Conn. Mar. 25, 2016) (Underhill,
J.) (awarding interest at a rate of 3.5% per year as reflective of the average bank
prime interest rate from July 2008 through March 2016); Nations Roof, LLC v.
Carnahan, 3:14-cv-1753, 2015 WL 3849241, at *2 (D. Conn. June 22, 2015) (Meyer,
J.) (awarding interest at a rate of 4% per annum “to account for the time-value of
the money” from April 1, 2015, and June 22, 2015); Cadle Co. v. Fletcher, 3:11-cv00794, 2014 WL 362469, at *4 (D. Conn. Aug. 13, 2014) (Underhill, J.) (awarding
interest at a rate of 4% per annum as reflective of the market conditions from 2007
through 2010). The current bank prime interest rate is 4.75%. See Selected Interest
Rates H.15, FED. RESERVE (June 1, 2018), https://www.federalreserve.gov/
releases/h15. Accordingly, the Court finds post-judgment interest in the amount
of 4.75% per annum appropriate in this case.
Case 3:18-cv-00058-VLB Document 22 Filed 06/04/18 Page 2 of 2
Accordingly, the Court hereby enters default judgment against ABW as to
breach of the implied warranty of merchantability and CUTPA, and denies the
motion to enter default judgment as to breach of express warranty. The Court
enters judgment in the total amount of $33,007.00, including both actual and
punitive damages, as well as post-judgment interest at the rate of 4.75% per annum.
IT IS SO ORDERED.
Hon. Vanessa L. Bryant
United States District Judge
Dated at Hartford, Connecticut: June 4, 2018
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