In 2010, the Arizona Court of Appeals recognized the “legal minefield” of bad faith claims that can plague insurers when faced with multiple claims that exceed the available liability policy limits. In McReynolds v. Am. Commerce Ins. Co., 225 Ariz. 125, 235 P.3d 278 (App. 2010), the defendant was insured under a policy with liability limits of $25,000. After a dispute arose between plaintiff’s counsel and the treating hospital over the satisfaction of a medical lien, plaintiff served an offer of judgement for the policy limits on the insurer. Instead of responding to the offer of judgment, however, the insurer promptly filed an interpleader action and paid the $25,000 policy limits into the court.