already affirmed the portion of the damages award that was not dependent on any tolling theory, see id. at 395, 406, so Rule 37(a), not Rule 37(b), governed post-judgment interest on those damages. Second, Mt. Hood I did not direct the entry of a particular, modified money judgment, but simply remanded to the district court to assess the equitable tolling theory. See Mt. Hood II, 616 F.2d at 395; Mt. Hood I, 583 F.2d at 469. Thus, Rule 37(b)’s limitation on the district court’s authority to award post-judgment interest was simply inapplicable in Mt. Hood II. Physicians may have been led astray by language in Mt. Hood II suggesting that we take an expansive approach to the award of post-judgment interest. See Mt. Hood II, 616 F.2d at 406-07; see also Handgards, 743 F.2d at 1299 & n. 26 (<HOLDING>). However, that language was addressed to the
recognizing a split of authority recognizing a split in the circuit as to whether objections to prudential standing can be waived and listing circuit cases recognizing circuit split recognizing split among district courts recognizing a split of authority on this issue