'Made-Whole' Doctrine Doesn't Apply to Carrier's Cross-Claims

The Wisconsin Court of Appeals ruled that the made-whole doctrine did not apply to the cross-claims asserted by an insurance carrier after it abandoned its original cross-claims based on subrogation. Case: Mani v. Selective Insurance Co. of America, No. 2023AP905, 01/21/2026, published. Facts: In 2015, Jack Mani suffered injuries in a car accident caused by an underinsured motorist. Because he was working at the time of the accident, Mani submitted a claim to his employer’s workers’ compensation carrier, AmTrust North America Inc. AmTrust initially paid for Mani’s accident...