State Farm Mutual Automobile Insurance Co. v. Bogart
In State Farm Mutual Automobile Insurance Co. v. Bogart, 149 Ariz. 145, 717 P.2d 449 (Ariz. 1986), at issue was whether the payment of the full amount of coverage provided under Hertz's car rental contract triggered excess insurance coverage under the driver's individual policy or his employer's policy.
After observing that under Arizona law "a self-insured car rental agency is treated as primarily responsible for liability arising from the use of its rented cars," the Supreme Court of Arizona concluded that "'other insurance' clauses are not triggered by the existence of primary, self-insured responsibility." 717 P.2d at 454.
The Court held "'self-insurer is not an insurer'" and "'a self-insurer does not insure liability other than its own'" without benefit of any contextual references. Id.