The Court of Appeals in LMK Psychological Servs., P.C. v. State Farm Mut. Auto. Ins. Co. (12 NY3d 217, 906 NE2d 1046, 879 NYS2d 14 [2009]) notably reversed the Appellate Division and addressed that issue in great detail. Upon careful analysis, they found that the accumulation of punitive interest should have been tolled. The Court of Appeals therefore reversed the decision of the Appellate Division and remitted the matter back to the Supreme Court for further proceedings in accordance with its opinion. That included an interest recalculation which does not include those periods in which the accumulation of interest was tolled.