Outside the cases of receivership, the Supreme Court of the United States has said: "We reach the conclusion that whatever may have been the English and early American rule, the tendency in Virginia as elsewhere in this country, is to allow interest on contracts to pay money from the date that the debt becomes due."'
Ralph E. Clark,
Interest on Claims in Receivership Proceedings,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol19/iss1/3