reimbursement clause (Washington) · Go Syfert
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reimbursement clause in Washington

7 Washington opinions name it 2 courts 1997–2022 1 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
Link v. Town of Smithtowngreen
nysupct · 1997 · cited in 2 Washington opinions naming this issue, 2000–2000
2 sentences

2000Id. at 694.

2000Id. at 694.The court considered both the state and federal statutes and concluded that all the settlement proceeds were available to satisfy the amount of reimbursement.

22
Keenan v. INDUSTRIAL INDEMNITY INS. CO. OF NORTHWESTgreen
wash · 1987 · cited in 2 Washington opinions naming this issue, 1997–1997
2 sentences

1997See also Keenan, 108 Wash.2d at 314 , 738 P.2d 270 (holding that, through enforcement of a reimbursement clause, an insurer may offset amounts previously paid to an insured under a PIP endorsement against amounts payable to the insured under a UIM endorsement, when the insured will be fully compensated for all damages even with the offset).

1997See also Keenan, 108 Wn.2d at 314 (holding that, through enforcement of a reimbursement clause, an insurer may offset amounts previously paid to an insured under a PIP endorsement against amounts payable to the insured under a UIM endorsement, when the insured will be fully compensated for all damages even with the offset).

22

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
In re the Marriage of White green
washctapp · 2001
1 sentence

2022Analysis This court addressed a similar reimbursement claim in White, 105 Wn.

12022–2022
Averill v. Farmers Insurance green
washctapp · 2010
1 sentence

2018Averill invokes the distinction in its search for a way to distinguish Sherry: "An offset such as in Sherry is akin to a reimbursement claim from a common fund and, unlike in this case, the made whole doctrine was triggered." Averill, 155 Wn.

12018–2018
Price v. Farmers Insurance green
washctapp · 1996
2 sentences

1997Price, 82 Wash.App. at 24 , 916 P.2d 949 .

1997Price, 82 Wash.App. at 24 , 916 P.2d 949 .

11997–1997

Statutes the citing opinions construe

WA § Wash. Rev. Code § 48.22.030 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 97 (1981–2025) CA 53 (1970–2026) LA 32 (1977–2025) IL 18 (1985–2015) AZ 11 (1992–2026) NY 9 (1988–2015) FL 8 (1980–2021) NJ 8 (1954–2017) WA 7 (1997–2022) MI 5 (1968–2009) IA 5 (2017–2020) AL 5 (2003–2024) OK 5 (1997–2008) NM 4 (1985–2018) OH 4 (1999–2006) IN 4 (1998–2018) WI 3 (1986–2020) AK 3 (1987–2013) MS 3 (2007–2011) MA 3 (1961–2026) MD 3 (1993–2012) UT 2 (2011–2013) TN 2 (1999–2021) VT 2 (2013–2013) MO 2 (1988–2012) PA 2 (1977–1977) KS 2 (1989–1994) VA 2 (1996–2017) SD 2 (2019–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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