Edmond v. Fairfield Sunrise Village, Inc

In Edmond v. Fairfield Sunrise Village, Inc., 132 Ariz. 142, 142, 644 P.2d 296, 296 (App. 1982), the Edmonds were injured when their car was struck by another vehicle driven by Carr. They sued Carr, recovered a judgment against her, and filed a satisfaction of judgment with the court. 132 Ariz. at 142, 644 P.2d at 296. The Edmonds then sued Fairfield, the owner of the vehicle Carr had been driving, seeking compensatory and punitive damages from the same accident. Id. at 143, 644 P.2d at 297. This court concluded that the Edmonds' claim for compensatory damages was precluded by the doctrine of satisfaction of judgment. Id. at 144, 644 P.2d at 298. And the Court ruled that the punitive damages claim likewise was barred. The Edmonds have satisfied the judgment, recovering their actual losses from Ms. Carr. They cannot now sue Fairfield for actual damages, because the satisfaction of judgment has extinguished the cause of action. A lawsuit for punitive damages only may not proceed once the cause of action for actual damages has been extinguished, actual damages being necessary to support punitive damages. Id.