upon proof of disability. Consequently, although plaintiff was later shown to be entitled to benefits beginning in mid-1995, defendant did not owe those benefits until the close of 1998, when plaintiff finally submitted sufficient proof of her disability. Defendant paid benefits to plaintiff when those benefits were due under the Plan’s terms. It is clear that an administrator’s adherence to a plan’s terms cannot constitute a plan breach. Moreover, since defendant paid plaintiff her benefits when they became due, she has, as a practical matter, no claim for interest. Interest accrues only when payment is due. Fotta v. Trustees of the United Mine Workers of America, 165 F.3d 209, 213 (3d Cir.1998); see also Stroh Container Co. v. Delphi Industries, Inc., 783 F.2d 743, 752 (8th Cir.1986) (<HOLDING>); Short v. Central States, Southeast &
holding that prejudgment interest is based on the amount of the judgment not the total amount of damages awarded by the jury because nonsettling defendants have no control over settlement negotiations and should not be forced to pay prejudgment interest on settling defendants parts of a damages award recognizing general rule that prejudgment interest may be awarded in claims for liquidated amounts holding that prejudgment interest should be awarded when the claimant has been denied the use of money which was legally due holding that a court may in its discretion award prejudgment interest in erisa cases where appropriate but it is not axiomatic that such interest should be awarded simply because  the prevailing party has demonstrated entitlement to the funds holding that prejudgment interest should not be added to damages awarded for misrepresentation because the amount of damages were not liquidated or ascertainable before the verdict