In Anderson v. National U. Fire Ins. Co., 476 Mass. 377, 67 N.E.3d 1232, 1235 (2017), a third-party bad faith case, the Supreme Judicial Court of Massachusetts held that in a bad-faith case in which a judgment was already recovered on the bad-faith claims, interest on that judgment is not tripled under Massachusetts law:
We conclude that in a case where the amount of actual damages to be multiplied due to a wilful or knowing violation of G. L. c. 93A or G L. c. 176D are based on the amount of an underlying judgment, that amount does not include postjudgment interest.
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