Worker Doesn't Need to Reach MMI to Challenge Carrier's Subrogation Claim

The Montana Workers’ Compensation Court ruled that a worker does not need to reach maximum medical improvement before he challenges a subrogation lien under the “made whole doctrine.” Case: Hogan v. Federated Mutual Insurance Co., No. 2020-5103, 09/02/2020, published. Facts and procedural history: Brady Hogan suffered an on-the-job injury while working for an employer with workers’ compensation insurance coverage with the Federated Mutual Insurance Co. Hogan obtained a recovery from a third-party at fault for his injuries, and Federated Mutual asserted a lien fo...