The Minnesota Court of Appeals considered the application of Minnesota’s prejudgment interest statute, Minn. Stat. § 549.09, subd. 1(b), finding it does not apply to appraisal awards made pursuant to the terms of an insurance policy without an underlying breach of contract or actionable wrongdoing. Poehler v. Cincinnati Insurance Company, A15-0958 (Minn. App. Jan. 25, 2016).