is consider proper in ERISA cases.”). This is because ERISA permits a participant to seek “appropriate equitable relief.” 29 U.S.C. § 1132(a)(3)(B); see also Allison, 289 F.3d at 1243 (“Prejudgment interest is appropriate when its award serves to compensate the injured party and its award is otherwise equitable.”). Calculation of the rate for prejudgment interest also “rests firmly within the sound discretion of the trial court.” Caldwell v. Life Ins. Co. of N. Am., 287 F.3d 1276, 1287 (10th Cir.2002); id. at 1287-88 (rejecting argument that 28 U.S.C. § 1961(a) rate should be applied in context of ERISA claim for prejudgment interest). Courts commonly look to state statutory prejudgment interest provisions as guidelines for a reasonable rate. See, e.g., Allison, 289 F.3d at 1244 (<HOLDING>); cf. Cottrill v. Sparrow, Johnson & Ursillo,
holding that the trial court did not abuse its discretion in awarding prejudgment interest on attorneys fees paid prior to the entry of judgment holding in patent litigation that district court did not abuse its discretion by awarding simple rather than compound prejudgment interest holding that district court did not abuse its discretion in awarding prejudgment interest at the colorado statutory rate of 8 percent holding in adea action that district court did not abuse its discretion by awarding compound rather than simple prejudgment interest holding that award and rate of prejudgment interest are within trial courts discretion