State ex rel. Indus. Com'n v. Word

Summary

The court held that the relevant "award" under A.R.S. § 23-907(E) was the original award granting benefits, not the later final accounting of payments. Filing the original award was necessary to create an eight-year judgment lien, but each payment from the Special Fund independently became a judgment without filing. Because the final payment occurred more than five years before the garnishments and the judgment was not renewed, the garnishments were unenforceable; the superior court was therefore reversed and the matter remanded with instructions to grant the Rule 60(c) motion.