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In Criado v. IBM Corp., 145 F.3d 437 (1st Cir. 1998), the court cited Hogan v. Bangor & Aroostock R. Co., 61 F.3d 1034, 1038 (1st Cir. 1995) for the proposition that "whether to award prejudgment interest is within discretion of district court."

In Gierlinger v. Gleason, 160 F.3d 858 (2d Cir. 1998), the court explained:

   In a suit to enforce a federal right, the question of whether or not to award prejudgment interest is ordinarily left to the discretion of the district court, see, e.g., Endico Potatoes, Inc. v. CIT Group/Factoring, Inc., 67 F.3d 1063, 1071-72 (2d Cir. 1995), which is to take into consideration "(i) the need to fully compensate the wronged party for actual damages suffered, (ii) considerations of fairness and the relative equities of the award, (iii) the remedial purpose of the statute involved, and/or (iv) such other general principles as are deemed relevant by the court," Securities & Exchange Commission v. First Jersey Securities, Inc., 101 F.3d 1450, 1476 (2d Cir. 1996) (internal quotation marks omitted), cert. denied, 118 S. Ct. 57 (1997); see, e.g., Wickham Contracting Co. v. Local Union No. 3, 955 F.2d 831, 833-34 (2d Cir.), cert. denied, 506 U.S. 946 (1992).

In Reed v. Mineta, 438 F.3d 1063 (10th Cir. 2006), the court explained:

   We review the district court's award of prejudgment interest for an abuse of discretion. See United States v. Crescent Amusement Co., 323 U.S. 173, 185 (1944); Caldwell v. Life Ins. Co. of N. Am., 287 F.3d 1276, 1286 (10th Cir. 2002). Accordingly, we will not reverse the decision of the district court unless it made an "arbitrary, capricious, whimsical, or manifestly unreasonable judgment." Schrier v. Univ. Of Colo., 427 F.3d 1253, 1258 (10th Cir. 2005) (quotation omitted). The abuse of discretion standard includes review to determine that the district court did not commit an error of law by applying an erroneous legal standard. See Winnebago Tribe of Neb. v. Stovall, 341 F.3d 1202, 1205 (10^th Cir. 2003).