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Collateral Estoppel Bars Police Officer From Challenging Subrogation of Third-Party Settlement

Tuesday, November 11, 2025 | 0

The Commonwealth Court of Pennsylvania ruled that collateral estoppel barred an injured police officer from challenging her employer’s subrogation of her third-party settlement. Case: Tiano v. City of Philadelphia (WCAB), No. 664 C.D. 2023, 11/03/2025, unpublished. Facts and procedural history: Barbara Tiano worked as a police officer for the City of Philadelphia. She suffered injuries after she fell into a utility hole while at work in October 2016, and the city paid Heart and Lung Act benefits in lieu of workers’ compensation. The HLA provides for the payment of full-sala...

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