For insurers and claims professionals, the practical signal is narrow but real. Where entitlement is fixed as of a date certain, the standard the court applied treats prejudgment interest as something the trial court must add, not a matter of discretion. Here, leaving it out was enough to reverse part of the ruling and send the award back, even though the rest of it stood. The takeaway is procedural, not dramatic, but it is the kind of detail that decides whether an award holds up.

