22
Opinion of O'Connor, J.
then, along with other courts, criticized the common law rule that prejudgment interest was recoverable on claims for liquidated, but not for unliquidated, damages. See ibid. But in the absence of a statute providing for such interest, many courts, including our own, still denied and would continue to deny prejudgment interest on claims for unliquidated and unascertainable damages in a great many, and probably most, circumstances. See, e. g., Board of Comm'rs of Jackson Cty. v. United States, 308 U. S. 343, 353 (1939); Blau v. Lehman, 368 U. S. 403, 414 (1962); Lineman v. Schmid, 32 Cal. 2d 204, 211, 195 P. 2d 408, 412 (1948) (Although "there is authority to the effect that the distinction formerly existing between liquidated and unliquidated demands is practically obliterated, . . . further reading . . . discloses, with citation of many cases, that the general rule is almost uniformly adhered to, namely, that interest is not allowable where the damages depend upon no fixed standard and cannot be made certain except by accord, verdict or decree"); D. Dobbs, Remedies § 3.5, p. 165 (1973) ("Most courts, in the absence of a statute to the contrary, would not award interest on unliquidated pecuniary claims, the amount of which could not be ascertained or computed, even in theory, without a trial"); see generally C. McCormick, Law of Damages § 51, p. 210 (1935) (explaining evolution of rule in America); see also 1 D. Dobbs, Law of Remedies § 3.6(1), p. 336 (2d ed. 1993) ("The most significant limitation on the recovery of prejudgment interest is the general rule that, apart from statute, prejudgment interest is not recoverable on claims that are neither liquidated as a dollar sum nor ascertainable by fixed standards" (footnotes omitted)).
Awards of such interest on claims for unliquidated and unascertainable damages for breach of a contract appear to have been rarer still. See, e. g., Williams v. Idaho Potato Starch Co., 73 Idaho 13, 24, 245 P. 2d 1045, 1051-1052 (1952); Meyer v. Strom, 37 Wash. 2d 818, 829-830, 226 P. 2d 218, 224 (1951); Lineman v. Schmid, supra, at 207-213, 195 P. 2d, at
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