32. Interest
 
    1. Interest/Postjudgment: "[O]nce a 'taking' has been properly reduced to a judgment, the constitutional requirement of 'just compensation' has been satisfied." Ergo, postjudgment interest is statutory, not constitutionally required, and the applicable statute is the one in effect at the time of the commencement of the action.  County of Clark v. Alper, 100 Nev. 382, 394-395, 685 P.2d 943 (1984) (#68)
 
    2. Interest/Prejudgment: The landowner is entitled to interest from the date of the taking (order for immediate occupancy).  Saunders v. State, 70 Nev. 480, 485, 273 P.2d 970 (1954) (#23)
 
    3. Interest/Prejudgment: "Where the market value of the property is not paid contemporaneously with the taking, the owner is entitled to interest for the delay in payment from the date of the taking until the date of the payment." Even where the court has also given the landowner the benefit of the appreciated later value at the time of trial! Interest compensates for the delay and deprivation of use of the proceeds; time of trial valuation "is merely an alternative method of valuing land in protracted condemnation proceedings."  County of Clark v. Alper, 100 Nev. 382, 392-393, 685 P.2d 943 (1984) (#68)
 
    4. Interest/Prejudgment: "The statutory interest rate establishes at least a prima facie basis for determining a fair rate and is not controlling if some other rate is required to meet the constitutional requirements of just compensation." Id. at 394 (#68)
 
    5. Interest/Prejudgment: "Statutory interest rates as applied to prejudgment interest are generally considered as a "floor" on the rate allowable for compensation under the fifth amendment." Id. at 394 (#68)
 
    6. Interest/Prejudgment: "The term 'just compensation' includes interest from the date of the taking [citing Manke, #63];  City of Sparks v. Armstrong, 103 Nev. 619, 623, 748 P.2d 7 (1987) (#74)
 
    7. Prejudgment/Interest: Because NRS 37.120(1) and 37.120(2) operate to destroy the only value of vacant, unimproved property, the taking occurs on the date of the service of summons, and interest shall be calculated from that time.  Manke v. Airport Authority, 101 Nev. 755, 758, 710 P.2d 80 (1985) (#70)
 
    8. Prejudgment/Interest: "If the condemned property is neither vacant, nor unimproved, nor of value to the condemnee for purposes of investment or development, the condemnee is only entitled to interest pursuant to NRS 37.175(2). Id. at 759, n. 6. (#70)
 
    9. Prejudgment/Interest: Incidental rents or profits from basically unimproved land accrued after the date of the service of summons, is to be subtracted from the interest, but the interest is still to run from the date of the service of summons. Id. 759, n. 6. (#70)

    10. Pre-condemnation interest: "In Clark County v. Alper, 100 Nev. 382, 685 P.2d 943 (1984), this court referred to the statutory rate as a floor on permissible rates...." (718) "This court further held that the determination of the proper interest rate is a question of fact, and that the district court was not bound by the statutory interest rate." (5) "We stated that just compensation requires that the landowner "'be put in as good position pecuniarily as he would have been if his property had not been taken.'...The purpose of awarding interest is to compensate the landowner for the delay in the monetary payment that occurred after the property had been taken." State, Dep't of Transp. v. Barsy, 113 Nev. 712, 718, 941 P.2d 971 (1997)

    11.  Pre-condemnation interest: "While the statutory rate should be used if unchallenged, once competent evidence is presented supporting another rate of interest as being more appropriate, the district judge must then determine which rate would permit the most reasonable interest rate." (Id. at 718)

    12.  Prejudgment interest: "The issue presented in this appeal was decided in State, Department of Transportation v. Barsy, 113 Nev. 712, 941 P.2d 971 (1997), where we held that NRS 37.175 does not preclude a higher rate of interest on judgments in condemnation cases if it is shown that a higher rate of interest is necessary to provide a reasonable rate of return." Roberts Trust v. County of Clark, 113 Nev. 832, 834, 942 P.2d 133 (1997)

    13. Prejudgment interest: In Barsy, "this court upheld a condemnee's right to receive a reasonable rate as prejudgment interest if competent evidence showed that a reasonable rate of interest would be other than that stated in NRS 37.175."  Id. at 834.