When Does Postjudgment Interest Start After Remand? Bruno v. Alliance Rental Group (AC 25-P-383, October 5, 2026)

A property owner who defeats inflated mechanic’s liens may still recover Chapter 93A damages even if he ends up with a net profit from the underlying transaction. And when an appellate court corrects a trial judge’s legal error by recalculating a money judgment using amounts already in the record, postjudgment interest runs from the date of the original judgment, not the remand judgment. Those are the two main holdings of the Appeals Court’s decision in Bruno v. Alliance Rental Group, LLC.

The Facts

In 2013, Michael Bruno hired Ivester Construction to perform subdivision improvements on property in North Reading. The contract covered road work and improvements to eleven lots on Charles Street. Bruno agreed to pay Ivester $300,000 on a distribution schedule and to transfer two lots (lots 6 and 7) to Ivester upon completion, with those lots valued at $900,000.

To do the work, Ivester rented an excavator and a loader from Alliance Rental Group. The owner of Alliance had known the owner of Ivester for about fifteen years and had previously made personal loans totaling $400,000 to him, funded through a home equity line of credit, with the understanding that Ivester would receive two lots when the project was done.

The construction dragged on. There were long periods of down time: a year waiting for a street permit, another year waiting for an electrical permit, time waiting for broken drains to be fixed. Town regulations prohibited subdivision construction between December 1 and March 15 each year. Both pieces of equipment were removed from the property for repairs, the excavator twice and the loader once. Ivester did not maintain daily logs tracking equipment use, so there was no documentary evidence of when the machinery was actually working.

Ivester never paid Alliance any rental fees. Alliance established mechanic’s liens on Bruno’s property totaling $697,479.06, including charges for periods when the equipment sat idle and charges for repairs.

The First Round of Litigation

Bruno sued under G. L. c. 254, § 15A, to dissolve the liens. He later amended his complaint to add a Chapter 93A claim, alleging that Alliance filed unmeritorious lien claims based on inflated fees. After a bench trial, the judge found that Bruno owed Alliance $180,000, not $697,479.06. That figure reflected the fair market value of the equipment during its actual use. The judge also ruled for Bruno on the c. 93A claim and awarded him $100,182 in damages (his attorney’s fees and costs), finding that Alliance, its owner, and Ivester had engaged in a scheme to extract money from Bruno well beyond any commercially justifiable amount. Judgment entered on August 9, 2021.

Both sides appealed. In August 2023, the Appeals Court held that the trial judge erred in reducing the liens to fair rental value. A mechanic’s lien under G. L. c. 254, § 4, is not so limited. The court amended the judgment to award Alliance $585,505, representing the total lien amount minus repair costs of $111,974.06. The court affirmed the validity of the liens and affirmed Bruno’s c. 93A award, but remanded the case for the trial judge to reconsider the appropriate amount of c. 93A damages in light of the opinion.

On Remand

By the time the case returned to Superior Court, the trial judge had retired. A new judge (the remand judge) held a nonevidentiary hearing in April 2024 and issued an order in October 2024. He awarded Bruno $505,687 on the c. 93A claim: $405,505 in damages (the portion of Alliance’s claimed rental charges that exceeded the $180,000 the trial judge had found reasonable) plus the original $100,182 in attorney’s fees and costs. With prejudgment interest of $253,216.70, the total judgment for Bruno came to $758,903.70. Six days later, a separate judgment entered for Alliance in the amount of $585,505, with no provision for interest.

Alliance moved for reconsideration under Mass. R. Civ. P. 59(e), arguing that Bruno suffered no cognizable injury under c. 93A and that Alliance was entitled to postjudgment interest from the date of the original 2021 judgment. The remand judge denied the motion, and Alliance appealed.

Jurisdiction

The court first addressed whether Alliance’s appeal was timely. Bruno argued that the appeal period began on October 10, 2024, when the remand judgment for Bruno entered, and that Alliance’s notice of appeal (filed February 26, 2025) came too late. Bruno also contended that Alliance’s rule 59(e) motion, served October 28, 2024, was itself untimely and therefore did not toll the appeal period.

The court disagreed. A judgment is not final for purposes of Mass. R. A. P. 4(a) until all claims against all parties have been resolved. The October 10 judgment disposed of Bruno’s c. 93A claim but left Alliance’s c. 254 claim unresolved. That judgment did not become final until October 16, 2024, when judgment entered for Alliance. Ten days later was a Saturday, so Alliance’s motion served the following Monday, October 28, satisfied the ten-day requirement of rule 59(e). That motion tolled the appeal clock until the motion was denied on January 29, 2025. Alliance filed its notice of appeal within thirty days of that denial, so the appeal was timely.

Chapter 93A Injury

Alliance argued that Bruno suffered no injury within the meaning of c. 93A because Bruno never transferred lots 6 and 7 (worth $900,000) to Ivester. Even after paying the full $585,505 to Alliance, Bruno still realized an effective savings of $314,495, so Alliance reasoned that Bruno came out ahead and sustained no loss.

The court rejected the argument on two grounds. First, the issue was outside the scope of the remand. The Appeals Court had remanded only for reconsideration of the amount of c. 93A damages, not for relitigation of whether Bruno had suffered a loss in the first place. The trial judge had already found that Bruno lost money or property, and the Appeals Court had affirmed that determination in the first appeal.

Second, even if the issue were properly before the court, Alliance’s theory failed on the merits. Under Auto Flat Car Crushers, Inc. v. Hanover Ins. Co., a plaintiff who establishes concrete monetary or property loss satisfies the actual-damages element of § 11 without having to prove that the loss remains uncompensated. Bruno paid lien bonds to cover the mechanic’s liens. He hired counsel and engaged in protracted litigation to protect his interests. Those expenditures constituted concrete loss.

Accepting Alliance’s theory would gut § 11. Subcontractors could engage in deceptive behavior in violation of c. 93A with the knowledge that, so long as other financial offsets left the property owner with no net loss, they would face no statutory liability. That outcome would undermine the statute’s twin goals of deterring misconduct and providing a remedy for those who suffer specific harm as a result of prohibited conduct.

Postjudgment Interest

Alliance argued that it was entitled to postjudgment interest from August 9, 2021, the date of the original trial-court judgment, not from October 16, 2024, the date of the remand judgment. The court agreed, drawing on federal precedent in the absence of controlling Massachusetts authority.

The general rule is that where a judgment is affirmed on appeal, postjudgment interest runs from the date judgment originally entered in the trial court. But the case presented a wrinkle: the appellate court had not simply affirmed the judgment; it had ordered the judgment increased by a specific amount. The question was whether that increase reset the clock for postjudgment interest.

Federal courts apply a well-established standard: the decision turns on the degree to which the original judgment was upheld or invalidated on appeal. The inquiry involves the extent to which liability and damages, as finally determined, were ascertained or established in the first judgment. When the essential legal and evidentiary basis for damages is established but the amount is recalculated after appeal, postjudgment interest accrues from entry of the first judgment.

That principle governed here. The trial judge originally awarded Alliance $180,000, reflecting the fair market value of actual equipment use and excluding repair costs. The Appeals Court affirmed the basic ruling that Alliance was entitled to recover on its mechanic’s liens. The appellate court held only that c. 254 did not authorize the trial judge to reduce Alliance’s recovery from the face value of the liens to an amount he found reasonable. Once that error was corrected (and repair costs excluded, as the trial judge had originally recognized), the correct amount was $585,505. All of those figures had been determined by the trial judge. The appellate court merely corrected a legal error using amounts already on the record.

The original judgment for Alliance was basically sound, with both evidentiary and legal support. Alliance’s mechanic’s liens were valid, apart from repair costs, but the judgment was too low because of the trial judge’s understandable but erroneous conclusion that c. 254 authorized him to reduce the recovery to commercially reasonable amounts. Postjudgment interest on the amended judgment of $585,505 should therefore be calculated from the date of the original judgment, August 9, 2021.

Attorney’s Fees

Bruno requested appellate attorney’s fees under c. 93A. A party that prevails on a c. 93A claim is statutorily entitled to recover reasonable appellate attorney’s fees and costs with respect to the claims on which it prevailed, provided the request was made in the brief. Bruno made that request and is entitled to fees associated with the c. 93A claim on appeal. Bruno also argued that Alliance’s appeal was frivolous and that he should recover fees on the remaining claims, but the court rejected that contention.

Why It Matters

The decision clarifies two important points. First, it confirms that a Chapter 93A plaintiff need not show that he remained uncompensated for his losses in order to recover statutory damages. The concrete loss itself is enough, even if other aspects of the transaction left the plaintiff better off overall. That holding prevents bad actors from escaping liability by pointing to unrelated financial benefits the plaintiff enjoyed.

Second, the decision adopts federal principles for calculating postjudgment interest after an appellate modification of a money judgment. When the trial court gets the facts right but makes a legal error in calculating damages, and the appellate court fixes that error using figures already in the record, postjudgment interest runs from the original judgment date. That rule protects the prevailing party from losing the time value of money because of the trial court’s mistake. The application of that standard will depend heavily on the facts of each case, but the core principle is now clear in Massachusetts: if the first judgment established the evidentiary and legal foundation for the damages ultimately awarded, postjudgment interest accrues from the first judgment, not the second.

Read the full opinion: Bruno v. Alliance Rental Group, LLC (AC-25-P-383, October 5, 2026).