In Haralson v. Fisher Surveying, Inc., 201 Ariz. 1, 3, P 6, 31 P.3d 114, 116 (2001), the tortfeasor died in a motor vehicle collision, and the plaintiff sued his estate. The court found "no logical reason why courts should allow a punitive award against a defendant who survives a judgment, but deny it where death occurs earlier." Id. at 4, P 16, 31 P.3d at 117. Haralson further rejected the idea that statutory "silence is an expression of legislative intent." Id. at 5, P 18, 31 P.3d at 118.