On April 3, 2025, the First Department issued a decision in Bloom v. Helmsley Spear, LLC, 2025 NY Slip Op. 01999, holding that pre-judgment interest should be awarded from the first date the defendant owed the plaintiff money, explaining:
Furthermore, the motion court properly granted prejudgment interest on the 170 Broadway deal based on the earliest ascertainable date the cause of action existed, which was when Bloom was owed, but not paid, his proportionate share of commissions that defendant received on February 1, 2019. The motion court also properly awarded prejudgment interest on Bloom’s unpaid share of the China Ting and WeWork deals, accruing from the dates defendant was due to receive commissions for those deals.
(Internal citations omitted).