Facts: Husband and Wife divorced after a long-term marriage with three children. The trial court divided the marital estate, named Wife the primary residential parent, and awarded Wife child support, transitional alimony, and attorney’s fees.

The marital home was awarded to Wife. The trial court valued the home at $700,000, subtracted a $49,000 HELOC, a $339,000 mortgage balance, and a $90,000 land gift from Wife’s family, leaving $111,000 in equity to each party.

Husband’s $111,000 share was reduced by $19,730 in unpaid child support, $10,000 in unpaid mortgage payments, and $3,000 for the vehicle awarded to him, leaving $78,270.

Per the trial court’s ruling, Husband’s $78,270 share was secured by a lien on the marital home and real property. The lien was inferior to any refinancing by Wife. It did not have to be paid until six months after the youngest child turned 18 or graduated from high school, whichever occurred later. If the home sold earlier, the lien had to be paid at closing.

Husband appealed, arguing that because he could not access that equity until a future date, the trial court should have awarded post-judgment interest.

On Appeal: The Court of Appeals affirmed the trial court’s judgment.

TCA § 47-14-102(8) defines “interest” as “compensation for the use or detention of, or forbearance to collect, money over a period of time.” TCA § 47-14-122 provides that interest is computed on every judgment from the day the judgment is entered.

The Court examined a few similar cases, including Williams v. Williams, No. E1999-02750-COA-R3-CV, 2000 WL 816821 (Tenn. Ct. App. June 23, 2000), a divorce case in which the husband received a lien payable upon sale of the marital home, but no later than the youngest child’s eighteenth birthday. The Williams court held that because the husband was not entitled to use the money until the home was sold, he was not entitled to post-judgment interest.

Applying that rule, the Court held Husband was not entitled to post-judgment interest because his right to the deferred equity had not matured and depended on future conditions:

Like the husband in Williams, [Husband] is not yet entitled to the use of the money he was awarded from the equity of the marital home. He is only entitled to utilize his share of the home equity under a certain set of conditions established in the trial court’s judgment, and those conditions have not yet been met. Therefore, the trial court properly declined to award post-judgment interest to [Husband].

Thus, Husband’s deferred lien did not accrue post-judgment interest because his right to payment had not matured. The trial court’s judgment was affirmed in all respects.

K.O.’s Comment: Post-judgment interest compensates a judgment creditor for the loss of use of money the creditor is entitled to use. When the judgment itself says the money is not due until a future event occurs, the right to interest generally does not begin until the right to payment matures.

That makes drafting important. If the goal is to avoid post-judgment interest on a deferred home-equity lien, the judgment should clearly say payment is not due until the stated future event occurs. If the goal is to have the lien accrue interest, the judgment should say that, too, including the interest rate, when interest starts, whether it compounds, and whether default changes anything.

Do not leave interest to inference. Say exactly when the money is due, whether interest accrues before that date, and what happens if the home is sold, refinanced, or retained past the triggering event.

Source: Sheppard v. Sheppard (Tennessee Court of Appeals, Eastern Section, June 26, 2026).

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