Diana Glazer v. State of Arizona, 423 P.3d 993

In 2012 a jury awarded Diana Glazer $7.8 million against the State for injuries from a car accident; the judgment was affirmed on appeal in Glazer I.
The Arizona Department of Administration intended to pay the judgment from the Risk Management Revolving Fund (Revolving Fund), but an accounting error temporarily caused payment from the Construction Insurance Fund (CIF); the Revolving Fund later reimbursed the CIF.
The State self-insures claims up to $7 million and purchases excess insurance to reimburse amounts above that retention; the excess insurer reimburses the State, not the claimant.
Parties disputed the interest rate accruing on the judgment while the appeal was pending: Glazer argued the higher statutory rate for judgments generally (§ 44-1201(B)) applied to the portion reimbursed by the insurer; the State argued the lower Revolving Fund rate (§ 41-622(F)) applied to the entire judgment.
The trial court granted summary judgment for the State; the court of appeals affirmed the Revolving Fund rate applied but held the $800,000 above the $7 million retention was not eligible for the reduced rate because it would be paid by the excess insurer.
The Arizona Supreme Court granted review to decide whether § 41-622(F) applies to the entire judgment paid from the Revolving Fund, including portions later reimbursed by excess insurance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does § 41-622(F)’s reduced interest rate apply to portions of a judgment later reimbursed by the State’s excess insurer?	Glazer: reduced rate applies only to self-insured (unreimbursed) portion; insured portion should bear the higher statutory rate.	State: the reduced rate applies to any judgment paid out of the Revolving Fund, including amounts later reimbursed by insurer.	Held: The reduced Revolving Fund rate applies to the entire judgment paid from the Revolving Fund, including portions later reimbursed by excess insurance.

Glazer v. State, 237 Ariz. 160 (affirming underlying judgment) (background and prior appeal)
Glazer v. State, 242 Ariz. 391 (App. 2017) (court of appeals decision affirmed in part and partially reversed on insurance-related interest calculation)
Premier Physicians Grp., PLLC v. Navarro, 240 Ariz. 193 (2016) (statutory interpretation reviewed de novo)
Stambaugh v. Killian, 242 Ariz. 508 (contextual reading of statutory language) (statutory construction principles)
Robinson v. Shell Oil Co., 519 U.S. 337 (1997) (plainness of statutory language judged by text and context)
Minjares v. State, 223 Ariz. 54 (App. 2009) (legislative history of § 41-622(F) supports application to judgments generally)