State v. Foy
In State v. Foy, 176 Ariz. 166, 169, 859 P.2d 789, 792 (App. 1993), the trial court had ordered interest on a restitution award to accrue from the date of sentencing, apparently believing interest on the judgment was included in the definition of "economic loss" as used in the statute governing restitution, 13-804. 176 Ariz. at 167, 859 P.2d at 790.
However, Division One rejected that view, finding the "legislature had narrowed the definition of 'economic loss,' as that term is used in reference to restitution," as evidenced by its explicit exclusion of unliquidated damages such as pain and suffering, punitive damages, and consequential damages. Id. at 170-71, 859 P.2d at 793-94; see also A.R.S. 13-105(16) (providing same definition of economic loss).
Thus, the Court concluded, interest did not represent a loss exclusively attributable to the commission of the offense and therefore could not be "imposed by the court on a restitution award in a criminal case." Foy, 176 Ariz. at 171, 859 P.2d at 794.