The made whole doctrine as well as the basic principles of subrogation emphasize the loss suffered by the insured. (Shutterstock) The Supreme Court of Washington has ruled that a first-party insurer, upon obtaining a partial recovery in a subrogation action, must reimburse its fault-free insureds for the full amount of their deductibles before any portion of the subrogation proceeds can be allocated to the insurer.
|The case details
On July 25, 2015, Lazuri Daniels was involved in a three-vehicle wreck near Federal Way, Washington. At the time, Daniels was insured by State Farm Mutual Automobile Insurance Company with a policy that included a $500 deductible.
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Steven A. Meyerowitz
Steven A. Meyerowitz, a Harvard Law School graduate, is the founder and president of Meyerowitz Communications Inc., a law firm marketing communications consulting company. He may be contacted at smeyerowitz@meyerowitzcommunications.com.
