Is substantial evidence or de novo review the applicable standard of review?

The parties dispute whether the applicable standard of review is substantial evidence or de novo review. We need not resolve this dispute. Under either standard of review, respondent's claim was unliquidated. "Obviously, diminution of market value caused by the easement is not a fixed nor [sic] computable sum. The evidence in the instant case demonstrates how difficult the ascertainment of that item may be. For the reasons stated the demand is unliquidated within the meaning of the section [Civil Code section 3287] . . . ." Overholtzer v. Northern Counties Title Ins. Co., supra, 116 Cal.App.2d at p. 128.) Thus, the date of the action's filing is the earliest date from which interest can run.

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