Metzler v. BCI Coca-Cola Bottling Co. of Los Angeles, Inc.
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Plaintiff filed a personal injury suit against Defendant, BCI Coca-Cola Bottling Co. BCI rejected Plaintiff’s offer of judgment to settle, and the case proceeded to trial. The jury rendered a verdict for Plaintiff and awarded her damages. The trial court entered a total award of $2,135,867, which included prejudgment interest under Ariz. R. Civ. P. 68(g) as a sanction against BCI for rejecting Plaintiff’s offer of judgment. At issue in this case was whether the prejudgment interest was interest on an “obligation” under Ariz. Rev. Stat. 44-1201(A) or interest on a judgment” under section 44-1201(B). The trial court concluded that the prejudgment interest awarded as a sanction pursuant to Rule 68(g) was interest on an “obligation,” thus entitling Plaintiff to the ten percent rate set forth in section 44-1201(A). The Supreme Court reversed, holding that the applicable rate for prejudgment interest under Rule 68(g) in this case was 4.25 percent based on section 44-1201(B).
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