Missouri Post-Judgment Interest Rate: How It's Calculated and What You're Owed

The Two Interest Rates

Missouri doesn't use a single post-judgment interest rate. Under RSMo 408.040, the rate depends on the type of case:

• Non-tort cases (most small claims — unpaid invoices, security deposits, breach of contract): 9% per year, unless the contract carries a higher rate, in which case that contract rate applies
• Tort cases (personal injury, property damage): the intended Federal Funds Rate plus 5%, with the applicable rate stated in the judgment and fixed once entered

Most small claims judgments fall into the non-tort category. The 9% rate is fixed by statute for judgments without a contract rate above 9%. It applies from the date the judge enters the judgment until the debtor pays in full.

When Interest Starts Running

Post-judgment interest begins accruing on the date the judgment is entered — not the date enforcement starts, not the date the 10-day appeal window closes. Even during the trial de novo appeal period under RSMo 482.365, interest is accumulating on the judgment balance.

If the debtor files an appeal and posts a supersedeas bond, the interest still accrues. The bond secures the judgment amount; it doesn't freeze the clock.

How to Calculate It

Missouri post-judgment interest is simple interest, not compound. For a 9% annual rate:

Daily interest = (Judgment balance × 0.09) ÷ 365

On a $3,000 judgment balance, that's $0.74 per day, or about $22.19 per month. Over six months of non-payment, the interest alone adds $133.15 to what the debtor owes.

The judgment balance includes the amount awarded on the day judgment is entered, including principal, prejudgment interest, costs, and fees. Later post-judgment costs are tracked separately and credited before post-judgment interest under RSMo 408.040.

The Payment Allocation Rule

When the debtor makes a partial payment — whether through a garnishment remittance, a voluntary check, or a court-ordered installment plan — Missouri follows the traditional American Rule of Accounting. Every payment is credited in this strict order:

1. Post-judgment costs — paid first
2. Accrued post-judgment interest — paid second
3. Remaining balance applied to the judgment balance — paid last

This matters because interest keeps accruing on the unpaid judgment balance until it's fully satisfied. A debtor making small monthly payments may find that most of each early payment goes to interest and costs rather than reducing the balance.

Tracking the Balance

If you have a continuous wage garnishment running, you're required to file a Statement of Judgment Balance (Form CV93) with the circuit clerk every six months. This filing must show the running total: original principal, all payments received (with dates), interest accrued, costs added, and the remaining balance.

Even without a continuous garnishment, maintaining a balance ledger is essential. When the debtor eventually pays in full, you'll need to confirm the exact payoff amount — and if they dispute your calculation, you'll need records to support it. The ledger is also what you'll reference when filing the satisfaction of judgment.

Interest on Different Enforcement Tools

The same interest rate applies regardless of which collection method produces the payment. Garnishment remittances, voluntary checks, sheriff's sale proceeds, and bank garnishment funds are all credited against the same running balance using the same allocation order.

If you have multiple garnishments running simultaneously (say, a wage garnishment and a bank garnishment), track all incoming payments on a single ledger. The total collected across all enforcement tools must not exceed the outstanding balance.

When the Rate Changes

For most non-tort small claims cases, the 9% rate stays constant unless the judgment is on a contract bearing a higher rate. For tort judgments, the applicable intended Federal Funds Rate plus 5% is fixed in the judgment and does not change afterward.

The Missouri Small Claims Judgment Collection Guide includes a post-judgment balance tracker you can use to log payments, calculate interest, and maintain the running ledger required for CV93 filings and satisfaction of judgment.

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