Made-Whole Doctrine Does Not Apply to First-Dollar Risk

The New Jersey Supreme Court ruled that the made-whole doctrine does not override an express agreement between parties to allow an insured to recover self-insured retention before a carrier could be reimbursed for its payments to an injured worker. Case: City of Asbury Park v. Star Insurance Co., Nos. A-20-19 and 083371, 06/29/2020, published. Facts: From February 2010 to February 2011, the City of Asbury Park had a workers’ compensation insurance policy with the Star Insurance Co. The policy included a "self-insured limit retention for workers' compensation" losses...