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3 June 2026

Employee Who Settled Qui Tam Action Receives Interest On Attorneys’ Fees From Time Of Entry Of Order

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The Ninth Circuit examined whether post-judgment interest on attorneys' fees should accrue from the date of settlement approval or from the date of the final fee order. The court addressed the critical question of when a judgment becomes sufficiently definite to trigger interest calculations in False Claims Act litigation.
United States Litigation, Mediation & Arbitration
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Thrower v. Academy Mortg. Corp., 172 F.4th 703 (9th Cir. 2026)

Gwen Thrower was awarded attorneys’ fees, expenses, and costs in her False Claims Act action against Academy Mortgage, her former employer. After the district court approved the settlement in the amount of $38.5 million (including $11.5 million to Thrower personally), it awarded Thrower $8.6 million in attorneys’ fees and $90,000 in expenses. Thrower also sought post‑judgment interest on the attorneys’ fees from the time of the court’s approval of the settlement (January 2023). However, the district court awarded post‑judgment interest on the attorneys’ fees from the time of the entry of the order in May 2024 and not from the time of the approval of the settlement. The Ninth Circuit affirmed the lower court’s judgment, holding that the May 2024 order was the only judgment that provided a “definite and certain designation of the amount” of attorneys’ fees owed to Thrower from which to calculate the interest payment.

Employee Who Settled Qui Tam Action Receives Interest On Attorneys’ Fees From Time Of Entry Of Order

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