Can a plaintiff recover prejudgment interest in a mandamus action?

Finding no bar to interest the court turned its attention to Civil Code section 3287, subdivision (a). "Civil Code section 3287, subdivision (a), ... authorizes the recovery of interest on damages which are certain or capable of being made certain by calculation, where the right to recover has vested on a particular day. In Mass v. Board of Education [1964] 61 Cal.2d 612 [39 Cal.Rptr. 739, 394 P.2d 579], we construed this statute as providing for prejudgment interest in actions based upon a general underlying monetary obligation, including the obligation of a governmental entity determined by way of mandamus. Since Mass our courts on numerous occasions have awarded prejudgment interest in mandamus proceedings brought to recover sums of money pursuant to a statutory obligation. [Citations.]

"Under section 3287, subdivision (a), as interpreted in Mass, supra, a claimant must satisfy three conditions for the recovery of interest in a mandamus action against the state: (1) There must be an underlying monetary obligation; (2) the recovery must be certain or capable of being made [223 Cal.App.3d 243] certain by calculation; and (3) the right to recovery must vest on a particular day." (Tripp v. Swoap, supra, 17 Cal.3d at pp. 681-682, 131 Cal.Rptr. 789, 552 P.2d 749, fn. omitted, italics added.)