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Subrogation Settlement

Marshall Dennehey

Employer’s Refusal to Compromise It’s Subrogation Lien During Pendency of a Tort Action Does Not Constitute Bad Faith Resulting in...

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Martha Garduno Mondragon v. Jo Jo Pizza (WCAB); No. 174 C.D. 2024; filed Jan. 6, 2025 - This case involved a claimant who sustained work injuries as a result of a slip and fall on ice in the employer’s parking lot. A Claim...more

Morris James LLP

Subrogation and UIM Claims: Unpacking the Recent Henry and Manz Decisions

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The Delaware Supreme Court's decisions in Henry I and Henry II have had a significant impact on workers’ compensation claims involving underinsured motorist (UIM) benefits. Here, we break down the complex issues surrounding...more

Tyson & Mendes LLP

Shining Light on Phantom Medical Bills–Lessons from Washington on Using Federal Hospital Price Transparency Rules to Fight Back

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How many of you reading this have had this experience: you get a settlement demand with hundreds of thousands of dollars in claimed hospital bills, but the actual amount owed by the claimant is redacted, or you are told by...more

Butler Weihmuller Katz Craig LLP

New York Court Emphasizes the Importance of Notice in Subrogation

An insurer generally acquires its insured’s rights against tortfeasors through subrogation. But what happens if the insured enters into a settlement and releases the responsible third party? Does the release extinguish the...more

White and Williams LLP

New York Court Holds Insurer Can Recover Before Insured Is Made Whole

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In State Farm Fire & Cas. Co. v. Tamagawa, Index No. 510977/2021, 2023 N.Y. Misc. Lexis 5434, the Supreme Court of New York considered whether an insurance carrier can settle its property subrogation lawsuit with the...more

White and Williams LLP

New York Preserves Subrogation Rights

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The insurer’s right of subrogation is equitable in nature, even if not based in contract. However, since the insurer steps into the shoes of its insured and is limited to the rights of its insured, an integral part of the...more

White and Williams LLP

Florida Court Gives Parties Assigned a Subrogation Claim a Math Lesson

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Although the focus of most subrogation cases is usually on proving liability, determining the appropriate measure of damages is just as important. Sometimes turning on a nuanced argument for recoverability, an adverse holding...more

Bricker Graydon LLP

Injured workers must inform BWC of third-party settlements

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The Ohio Supreme Court recently ruled that the Ohio Bureau of Workers’ Compensation (BWC) must be notified of potential third-party settlements that would compensate an injured worker for an injury, even when an application...more

Robinson+Cole ERISA Claim Defense Blog

Second Circuit Clarifies New York Anti-Subrogation Law Prohibits Offsets For Settlements; Declares Plan’s Choice-of-Law Provisions...

The U.S. Court of Appeals for the Second Circuit has ruled that New York’s anti-subrogation statute, N.Y. Gen. Oblig. Law § 5-335(a), applies both to “offsets” for prospective benefit payments and to reimbursements for prior...more

Faegre Drinker Biddle & Reath LLP

Recovery of Medical Bills: Once Is Enough

Strange as it sounds, Missouri state law allowed federal workers to recover medical bills twice: once under their federal health insurance plan and again from the person (or person’s insurer) responsible for their injuries. ...more

Dorsey & Whitney LLP

The Supreme Court - April 18, 2017

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Coventry Health Care of Missouri, Inc. v. Nevils, No. 16-149: The Office of Personnel Management (“OPM”) is authorized under the Federal Employees Health Benefits Act of 1959 (“FEHBA”), 5 U.S.C. §8901 et seq., to contract...more

Butler Weihmuller Katz Craig LLP

Eleventh Circuit Finds Insurer Liable for Medicare Lien Notwithstanding Insurer's Efforts to Satisfy the Lien in Settlement, also...

In a case with far-reaching implications, the Eleventh Circuit Court of Appeals issued an opinion concluding that the Medicare Secondary Payer Act (MSP) permits a private insurance company/PART C Medicare Advantage...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - March 2016

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Editor’s Overview - This month we review the U.S. Supreme Court’s decision in Montanile v. Board of Trustees of National Elevator Industries Health Benefit Plan where the Supreme Court considered the scope of...more

Parker Poe Adams & Bernstein LLP

Supreme Court Says No Subrogation Claims from Health Plan After Participant Spends Settlement

On January 20, the Supreme Court released its decision in Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, concluding that although health plan fiduciaries can generally seek subrogation...more

Eversheds Sutherland (US) LLP

Supreme Court: For ERISA Plans, Time May Be Money

A new U.S. Supreme Court decision is a reminder that Employee Retirement Income Security Act (ERISA) plans must act promptly if they want to assert a lien to secure a participant’s obligation to reimburse medical expenses or...more

Cozen O'Connor

Supreme Court Sends ERISA Plans Racing to the Courthouse for Subrogation Recoveries

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The Supreme Court of the United States recently handed down a decision that opens the door for participants in ERISA-covered benefits plans to stop a lawsuit against them in its tracks by doing something that most people love...more

McDermott Will & Emery

Supreme Court Issues Further Clarification on Equitable Relief Remedies Available Under ERISA

McDermott Will & Emery on

ERISA Section 502(a)(3) empowers plan fiduciaries to file suit “to obtain … appropriate equitable relief … to enforce … the terms of the plan.” In 1993, the Supreme Court of the United States interpreted this ERISA provision...more

Proskauer - Employee Benefits & Executive...

U.S. Supreme Court Holds ERISA Plan Cannot Enforce Equitable Lien Against Participant’s General Assets

On January 20, 2016, the U.S. Supreme Court reversed a decision by the Eleventh Circuit and held that when a ERISA plan participant obtains a third-party settlement subject to a plan’s subrogation provision, and then...more

Baker Donelson

Deepwater Horizon Update: Fifth Circuit Rules in Favor of Cameron on Insurance Issues

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The U.S. Court of Appeals for the Fifth Circuit recently issued an opinion ruling in favor of Cameron International Corporation and certifying a question to the Texas Supreme Court on issues arising out of an insurance...more

Carlton Fields

Get Exhausted! The Tenth Circuit Schools an Excess Insurer on How to Preserve Subrogation Claims in a Settlement

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Claims against insured businesses sometimes implicate multiple liability policies issued by several different carriers, and it is sometimes prudent for some of those carriers to settle the underlying action, even if others...more

Orrick, Herrington & Sutcliffe LLP

Policy Observer - July 2013

Getting Over the Bar: Second Circuit Requires Actual Payment of Underlying Limits In Order to Trigger Excess D&O Policies - In June, the Second Circuit held that two Federal Insurance Company ("FIC") excess D&O...more

Davis Wright Tremaine LLP

ERISA Litigation Alert: Check Your Plan Subrogation and Reimbursement Language to Eliminate “Contractual Gaps”

In U.S. Airways v. McCutchen, the U.S. Supreme Court upheld the ability of U.S. Airways’ health plan to recover medical expenses that it previously paid to the injured party from a third party settlement, but remanded the...more

King & Spalding

Supreme Court Will Not Review Sixth Circuit Ruling That Government May Seek Full Reimbursement of Medicare Payments to Beneficiary...

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On October 1, 2012, the United States Supreme Court said it would not review a decision by the U.S. Court of Appeals for the Sixth Circuit which ruled 2-1 that, upon settlement by a Medicare beneficiary with a third-party...more

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