In Duke v. Cochise County, 189 Ariz. 35, 41, 938 P.2d 84, 90 (App. 1996), a surviving spouse brought an action on her own behalf and that of her adult children for the wrongful death of her husband; she also asserted personal claims for false imprisonment and emotional distress. 189 Ariz. at 37, 938 P.2d at 86. She offered to confess judgment for $ 2 million, but the defendant declined. Id. at 40, 938 P.2d at 89. The Court held that one receiving an unapportioned joint offer cannot make a meaningful choice between accepting the offer on any single claim or continuing the litigation . . . on all claims. Imposing sanctions for failing to accept what is in effect an unspecified and unapportioned offer of judgment deprives the offeree of the opportunity to assess his or her chances of doing better at trial against one or more of the parties covered by the joint offer. Id. at 41, 938 P.2d at 90. Because the Rule uses the singular form of "offer," an unapportioned joint offer was invalid. Id. The Court held that imposition of Rule 68 sanctions cannot be based on an unapportioned joint offer of settlement from multiple parties. Although we relied primarily on the rule's language specifying only a single "party" and "offer," we also stated: An offeree presented with an unapportioned joint offer cannot make a meaningful choice between accepting the offer on any single claim or continuing the litigation to judgment on all claims. Imposing sanctions for failing to accept what is in effect an unspecified and unapportioned offer of judgment deprives the offeree of the opportunity to assess his or her chances of doing better at trial against one or more of the parties covered by the joint offer. Id. at 41, 938 P.2d at 90. Albeit on different facts, in Duke the Court recognized that it is not proper to sanction a party when that party has no meaningful opportunity to avoid the sanction. When a party is unable, due to a 23-1023 lien, to accept an offer of judgment that it would have otherwise accepted, that party cannot make a meaningful choice--it has been forced to proceed with litigation it intended to end by accepting the defendant's offer of judgment.