Error in denial of pre-judgment interest as part of the judgment must be preserved for appellate review, 14th Court says

A complaint regarding the award of pre-judgment interest must be preserved in the trial court by a motion to amend or correct the judgment or by a motion for new trial. See Keith v. Keith, 221 S.W.3d 156, 173 (Tex. App.-Houston [1st Dist.] 2006, no pet.); see also Allright, Inc. v. Pearson, 735 S.W.2d 240, 240 (Tex. 1987) (per curiam) (error regarding award of pre-judgment interest must be preserved); Miller v. Kendall, 804 S.W.2d 933, 944 (Tex. App.-Houston [1st Dist.] 1990, no writ) (motion to amend or correct judgment or motion for new trial is proper vehicle for preserving error in judgment). The Nguyens failed to object to the trial court regarding the award of post-but not pre-judgment interest, and such failure waived this issue for appellate review. See Keith, 221 S.W.3d at 173; see also TEX. R. APP. P. 33.1(a)(1). We overrule the Nguyens' first issue on cross-appeal.

SOURCE: FOURTEENTH COURT OF APPEALS - No. 14-11-00126-CV - 5/17/12 (substituted opinion) (Cross-appellants argued that the trial court abused its discretion in failing to award pre-judgment interest, despite finding that they were entitled to such interest.)