PIP claim in Washington

6 Washington opinions name it 2 courts 2006–2019 0 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 (1)

Case	Followed	Cited
Nobl Park, L.L.C. v. Shell Oil Co.green washctapp · 2004 · cited in 1 Washington opinions naming this issue, 2017–2017 2 sentences 2017The Illinois state court system was the appropriate avenue for continuing to challenge the certifying court's determination of adequate representation.42 39 Lebanon Chiropractic, 2016 WL 546909 , at 13-14. 40 Id. at 11 ("[I]n his appellate briefs, Kerbs notes that Illinois is an at-fault state where Washington is a no-fault state, Illinois has no comparable PIP statute requiring the payment of all reasonable medical expenses submitted, and Illinois has no comparable insurance regulation requiring insurers to investigate a PIP claim before refusing to pay a claim.") 41 Id. 42 See Nobl Park, 12 2017The Illinois state court system was the appropriate avenue for continuing to challenge the certifying court's determination of adequate representation.42 39 Lebanon Chiropractic, 2016 WL 546909 , at 13-14. 40 Id. at 11 ("[I]n his appellate briefs, Kerbs notes that Illinois is an at-fault state where Washington is a no-fault state, Illinois has no comparable PIP statute requiring the payment of all reasonable medical expenses submitted, and Illinois has no comparable insurance regulation requiring insurers to investigate a PIP claim before refusing to pay a claim.") 41 Id. 42 See Nobl Park, 12	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

Case	Cited	Years
Price v. Farmers Insurance green wash · 1997 2 sentences 2006Price, 133 Wn.2d at 493 . 2006Price, 133 Wash.2d at 493 , 946 P.2d 388 .	2	2006–2006
Mahler v. Szucs green wash · 1998 2 sentences 2006Co., 115 Wn.2d 679, 682 , 801 P.2d 207 (1990). ¶16 Both Sherry and FIC agree that under Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 (1998), an insurer like FIC may contract for the right to be reimbursed for payments made under a PIP clause if the insured, Sherry, recovers money from the tortfeasor. 2006Co., 115 Wash.2d 679, 682 , 801 P.2d 207 (1990). ¶ 16 Both Sherry and FIC agree that under Mahler v. Szucs, 135 Wash.2d 398 , 957 P.2d 632 (1998), an insurer like FIC may contract for the right to be reimbursed for payments made under a PIP clause if the insured, Sherry, recovers money from the tortfeasor.	2	2006–2006
Mahler v. Szucs green wash · 1998 2 sentences 2006Co., 115 Wn.2d 679, 682 , 801 P.2d 207 (1990). ¶16 Both Sherry and FIC agree that under Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 (1998), an insurer like FIC may contract for the right to be reimbursed for payments made under a PIP clause if the insured, Sherry, recovers money from the tortfeasor. 2006Co., 115 Wash.2d 679, 682 , 801 P.2d 207 (1990). ¶ 16 Both Sherry and FIC agree that under Mahler v. Szucs, 135 Wash.2d 398 , 957 P.2d 632 (1998), an insurer like FIC may contract for the right to be reimbursed for payments made under a PIP clause if the insured, Sherry, recovers money from the tortfeasor.	2	2006–2006
Roller v. Stonewall Insurance green wash · 1990 2 sentences 2006Co., 115 Wn.2d 679, 682 , 801 P.2d 207 (1990). ¶16 Both Sherry and FIC agree that under Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 (1998), an insurer like FIC may contract for the right to be reimbursed for payments made under a PIP clause if the insured, Sherry, recovers money from the tortfeasor. 2006Co., 115 Wn.2d 679, 682 , 801 P.2d 207 (1990). ¶16 Both Sherry and FIC agree that under Mahler v. Szucs, 135 Wn.2d 398 , 957 P.2d 632 (1998), an insurer like FIC may contract for the right to be reimbursed for payments made under a PIP clause if the insured, Sherry, recovers money from the tortfeasor.	2	2006–2006
St. Paul Fire & Marine Insurance v. Onvia, Inc. green wash · 2008 2 sentences 2019Co. v. Onvia, Inc., 165 Wash.2d 122 , 129, 196 P.3d 664 (2008) )). ¶ 10 By making the PIP claim on the tortfeasor's insurance company, the insurance company is also the pedestrian's insurer. 2019Co. v. Onvia, Inc., 165 Wash.2d 122 , 129, 196 P.3d 664 (2008) )). ¶ 10 By making the PIP claim on the tortfeasor's insurance company, the insurance company is also the pedestrian's insurer.	1	2019–2019
St. Paul Fire and Marine Ins. Co. v. Onvia, Inc. green wash · 2008 2 sentences 2019Co. v. Onvia, Inc., 165 Wash.2d 122 , 129, 196 P.3d 664 (2008) )). ¶ 10 By making the PIP claim on the tortfeasor's insurance company, the insurance company is also the pedestrian's insurer. 2019Co. v. Onvia, Inc., 165 Wash.2d 122 , 129, 196 P.3d 664 (2008) )). ¶ 10 By making the PIP claim on the tortfeasor's insurance company, the insurance company is also the pedestrian's insurer.	1	2019–2019
Harris v. Drake green wash · 2004 2 sentences 2018Similarly, an independent medical examination required by a PIP claim was the work product of the insurer and was not discoverable by 5 No. 34671-4-111 Diaz v. Mariscal a third party once the insurance company asserted the privilege. 3 Harris v. Drake, 152 Wn.2d 480, 492 , 99 P.3d 872 (2004). 2018Similarly, an independent medical examination required by a PIP claim was the work product of the insurer and was not discoverable by 5 No. 34671-4-111 Diaz v. Mariscal a third party once the insurance company asserted the privilege. 3 Harris v. Drake, 152 Wn.2d 480, 492 , 99 P.3d 872 (2004).	1	2018–2018
Harris v. Drake green wash · 2004 2 sentences 2018Similarly, an independent medical examination required by a PIP claim was the work product of the insurer and was not discoverable by 5 No. 34671-4-111 Diaz v. Mariscal a third party once the insurance company asserted the privilege. 3 Harris v. Drake, 152 Wn.2d 480, 492 , 99 P.3d 872 (2004). 2018Similarly, an independent medical examination required by a PIP claim was the work product of the insurer and was not discoverable by 5 No. 34671-4-111 Diaz v. Mariscal a third party once the insurance company asserted the privilege. 3 Harris v. Drake, 152 Wn.2d 480, 492 , 99 P.3d 872 (2004).	1	2018–2018
Dreiling v. Jain green wash · 2004 2 sentences 2017Dreiling v. Jain, 151 Wn.2d 900, 907 , 93 P.3d 861 (2004). 5 At oral argument, GEICO agreed that it is not seeking review of the discovery of the claims file, the PIP claim, or any post-litigation materials that were inadvertently submitted for in camera review by the trial court. 6 48805-1-II II. 2017Dreiling v. Jain, 151 Wn.2d 900, 907 , 93 P.3d 861 (2004). 5 At oral argument, GEICO agreed that it is not seeking review of the discovery of the claims file, the PIP claim, or any post-litigation materials that were inadvertently submitted for in camera review by the trial court. 6 48805-1-II II.	1	2017–2017
Dreiling v. Jain green wash · 2004 2 sentences 2017Dreiling v. Jain, 151 Wn.2d 900, 907 , 93 P.3d 861 (2004). 5 At oral argument, GEICO agreed that it is not seeking review of the discovery of the claims file, the PIP claim, or any post-litigation materials that were inadvertently submitted for in camera review by the trial court. 6 48805-1-II II. 2017Dreiling v. Jain, 151 Wn.2d 900, 907 , 93 P.3d 861 (2004). 5 At oral argument, GEICO agreed that it is not seeking review of the discovery of the claims file, the PIP claim, or any post-litigation materials that were inadvertently submitted for in camera review by the trial court. 6 48805-1-II II.	1	2017–2017
Pappas v. Holloway green wash · 1990 2 sentences 2017ATTORNEY-CLIENT PRIVILEGE AND WORK PRODUCT “The attorney-client privilege applies to communications and advice between an attorney and client and extends to documents which contain a privileged communication.” Pappas v. Holloway, 114 Wn.2d 198, 203 , 787 P.2d 30 (1990); RCW 5.60.060(2)(a). 2017ATTORNEY-CLIENT PRIVILEGE AND WORK PRODUCT “The attorney-client privilege applies to communications and advice between an attorney and client and extends to documents which contain a privileged communication.” Pappas v. Holloway, 114 Wn.2d 198, 203 , 787 P.2d 30 (1990); RCW 5.60.060(2)(a).	1	2017–2017
Price v. Farmers Ins. Co. green wash · 1997 1 sentence 2006Price, 133 Wash.2d at 493 , 946 P.2d 388 .	1	2006–2006

Where else courts name it

FL 44 (1977–2026) NJ 34 (1979–2025) MI 23 (1992–2026) MA 23 (1996–2014) OR 10 (2007–2025) MD 9 (1992–2018) WA 6 (2006–2019) CO 6 (1988–2012) TX 3 (2001–2018) GA 2 (1984–1992) DE 2 (1982–2013) OH 2 (2011–2012)

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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