Ohio Revised Code

Ohio Rev. Code § 4123.93 (2026)

Subrogation definitions

✓ current as of May 2026
Find cases: SyfertCases citing this section ORCcodes.ohio.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar

As used in sections 4123.93 to 4123.932 of the Revised Code:

(A) "Claimant" means a person who is eligible to receive compensation, medical benefits, or death benefits under this chapter or Chapter 4121., 4127., or 4131. of the Revised Code.

(B) "Statutory subrogee" means the administrator of workers' compensation, a self-insuring employer, or an employer that contracts for the direct payment of medical services pursuant to division (P) of section 4121.44 of the Revised Code.

(C) "Third party" means an individual, private insurer, public or private entity, or public or private program that is or may be liable to make payments to a person without regard to any statutory duty contained in this chapter or Chapter 4121., 4127., or 4131. of the Revised Code.

(D) "Subrogation interest" includes past, present, and estimated future payments of compensation, medical benefits, rehabilitation costs, or death benefits, and any other costs or expenses paid to or on behalf of the claimant by the statutory subrogee pursuant to this chapter or Chapter 4121., 4127., or 4131. of the Revised Code.

(E) "Net amount recovered" means the amount of any award, settlement, compromise, or recovery by a claimant against a third party, minus the attorney's fees, costs, or other expenses incurred by the claimant in securing the award, settlement, compromise, or recovery. "Net amount recovered" does not include any punitive damages that may be awarded by a judge or jury.

(F) "Uncompensated damages" means the claimant's demonstrated or proven damages minus the statutory subrogee's subrogation interest.

Notes of Decisions
Cited in 45 cases (4 in the last 5 years), 1958–2026 · leading case: Ohio Bureau of Workers' Comp. v. McKinley, 2011 Ohio 4432 (Ohio 2011).
Sort: Relevance Newest Treatment
Ohio Bureau of Workers' Comp. v. McKinley, 2011 Ohio 4432 (Ohio 2011). · cites it 24× “1 {¶ 6} On November 4, 2008, the bureau filed suit in Columbiana County Common Pleas Court against McKinley and Heritage, asserting that they were jointly and severally liable under R.C. 4123.93 and 4123.931 for failing to honor the bureau’s subrogation lien in the settlement…”
Groch v. Gen. Motors Corp., 117 Ohio St. 3d 192 (Ohio 2008). · cites it 21× “For the reasons that follow, we answer the certified questions by holding that R.C. 4123.93, 4123.931, 2305.10(C), and former 2305.”
Modzelewski v. Yellow Freight Sys., Inc., 102 Ohio St. 3d 192 (Ohio 2004). · cites it 42× “{¶ 1} This appeal involves the constitutionality of former R.C. 4123.93, which again became effective when we declared its successor, R.”
Thomas v. Logue, Admr. of Ohio Bur. of Workers' Comp., 2022 Ohio 1603 (Ohio Ct. App. 2022). · cites it 17× “36 from appellant's settlement pursuant to R.C. 4123.93 and 4123.931. BWC's asserted subrogation interest was based in part on a list of medical bills in the amount of $5,544.”
McKinley v. Ohio Bureau of Workers' Comp., 866 N.E.2d 527 (Ohio Ct. App. 2006). · cites it 25× “{¶ 1} The Ohio Bureau of Workers’ Compensation appeals the decision of the Washington County Court of Common Pleas, holding R.C. 4123.93 and 4123.931 unconstitutional.”
Thomas v. Logue, 2023 Ohio 3522 (Ohio 2023). · cites it 16× “{¶ 27} The phrase “on behalf of” is not defined by R.C. 4123.93. “When a term is undefined, we give the term its ‘plain and ordinary meaning.”
McKinney v. Omni Die Casting, Inc., 2017 Ohio 2949 (Ohio Ct. App. 2017). · cites it 23× “The BWC argued R.C. 4123.93 and R.C. 4123.931 create an independent right of recovery in favor of a statutory subrogee, here, the BWC, against a third party who may be liable to McKinney for his injuries.”
Modzelewski v. Yellow Freight Sys., Inc., 785 N.E.2d 501 (Ohio Ct. App. 2003). · cites it 31× “II ASSIGNMENT OF ERROR {¶ 6} “The trial court erred when it granted summary judgment against United Parcel Service, and concluded that R.C. 4123.93 was unconstitutional.” {¶ 7} In its sole assignment of error, appellant asserts that the trial court erred when it granted summary…”
State ex rel. United Auto., Aerospace & Agric. Implement Workers of Am. v. Ohio Bureau of Workers' Comp., 108 Ohio St. 3d 432 (Ohio 2006). · cites it 7× “2d 1111 , despite holding the statute unconstitutional, we expressly noted that workers’ compensation subrogation statutes are not per se unconstitutional and that we were addressing only the specific provisions in former R.”
Smith v. Jones, 889 N.E.2d 141 (Ohio Ct. App. 2007). · cites it 9× “Additionally, Smith alleged that the workers’ compensation subrogation statutes, R.C. 4123.93 and 4123.931, were unconstitutional on their face and as applied to her, and she requested a declaratory judgment.”
Stolz v. J & B Steel Erectors, Inc. (Slip Opinion), 2016 Ohio 1567 (Ohio 2016). · cites it 3× “278, 146 Ohio Laws, Part II, 3581, 3595-3597; setting forth rights of subrogation with respect to a workers’ compensation claimant’s claims against third-party tortfeasors); R.C. 4123.93 (defining claimant, statutory subrogee, and third party for purposes of subrogation…”
Kaminski v. Metal & Wire Prods. Co., 2010 Ohio 1027 (Ohio 2010). · cites it 2× “See Groch at ¶ 28. 23 SUPREME COURT OF OHIO {¶ 72} We observed that concerns about the statute’s diminishing or extinguishing the claimant’s tort recovery were not relevant to an analysis under Section 35 because the statute did not affect the claimant’s workers’ compensation.”
Show all 45 citing cases →
— Ohio Rev. Code § 4123.93(A) — 5 cases
Ohio Bureau of Workers' Comp. v. McKinley, 2011 Ohio 4432 (Ohio 2011). “1 {¶ 6} On November 4, 2008, the bureau filed suit in Columbiana County Common Pleas Court against McKinley and Heritage, asserting that they were jointly and severally liable under R.C. 4123.93 and 4123.931 for failing to honor the bureau’s subrogation lien in the settlement…”
Bur. of Workers' Comp. v. Verlinger (Slip Opinion), 2018 Ohio 1481 (Ohio 2018).
Thomas v. Logue, 2023 Ohio 3522 (Ohio 2023). “{¶ 27} The phrase “on behalf of” is not defined by R.C. 4123.93. “When a term is undefined, we give the term its ‘plain and ordinary meaning.”
Ohio Bur. of Workers' Comp. v. Verlinger, 2016 Ohio 8029 (Ohio Ct. App. 2016).
Ohio Bur. of Workers' Comp. v. Petty, 2016 Ohio 5753 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 4123.93(B) — 13 cases
Ohio Bureau of Workers' Comp. v. McKinley, 2011 Ohio 4432 (Ohio 2011). “1 {¶ 6} On November 4, 2008, the bureau filed suit in Columbiana County Common Pleas Court against McKinley and Heritage, asserting that they were jointly and severally liable under R.C. 4123.93 and 4123.931 for failing to honor the bureau’s subrogation lien in the settlement…”
Groch v. Gen. Motors Corp., 117 Ohio St. 3d 192 (Ohio 2008). “For the reasons that follow, we answer the certified questions by holding that R.C. 4123.93, 4123.931, 2305.10(C), and former 2305.”
Holeton v. Crouse Cartage Co., 748 N.E.2d 1111 (Ohio 2001).
Bur. of Workers' Comp. v. Verlinger (Slip Opinion), 2018 Ohio 1481 (Ohio 2018).
State ex rel. United Auto., Aerospace & Agric. Implement Workers of Am. v. Ohio Bureau of Workers' Comp., 108 Ohio St. 3d 432 (Ohio 2006). “2d 1111 , despite holding the statute unconstitutional, we expressly noted that workers’ compensation subrogation statutes are not per se unconstitutional and that we were addressing only the specific provisions in former R.”
— Ohio Rev. Code § 4123.93(C) — 2 cases
McKinney v. Omni Die Casting, Inc., 2017 Ohio 2949 (Ohio Ct. App. 2017). “The BWC argued R.C. 4123.93 and R.C. 4123.931 create an independent right of recovery in favor of a statutory subrogee, here, the BWC, against a third party who may be liable to McKinney for his injuries.”
Ohio Bureau of Workers' Comp. v. McKinley, 2011 Ohio 4432 (Ohio 2011). “1 {¶ 6} On November 4, 2008, the bureau filed suit in Columbiana County Common Pleas Court against McKinley and Heritage, asserting that they were jointly and severally liable under R.C. 4123.93 and 4123.931 for failing to honor the bureau’s subrogation lien in the settlement…”
— Ohio Rev. Code § 4123.93(C)(3) — 1 case
Jones v. Xenia, 2011 Ohio 5545 (Ohio Ct. App. 2011).
— Ohio Rev. Code § 4123.93(D) — 14 cases
Thomas v. Logue, Admr. of Ohio Bur. of Workers' Comp., 2022 Ohio 1603 (Ohio Ct. App. 2022). “36 from appellant's settlement pursuant to R.C. 4123.93 and 4123.931. BWC's asserted subrogation interest was based in part on a list of medical bills in the amount of $5,544.”
Thomas v. Logue, 2023 Ohio 3522 (Ohio 2023). “{¶ 27} The phrase “on behalf of” is not defined by R.C. 4123.93. “When a term is undefined, we give the term its ‘plain and ordinary meaning.”
Modzelewski v. Yellow Freight Sys., Inc., 102 Ohio St. 3d 192 (Ohio 2004). “{¶ 1} This appeal involves the constitutionality of former R.C. 4123.93, which again became effective when we declared its successor, R.”
Groch v. Gen. Motors Corp., 117 Ohio St. 3d 192 (Ohio 2008). “For the reasons that follow, we answer the certified questions by holding that R.C. 4123.93, 4123.931, 2305.10(C), and former 2305.”
Modzelewski v. Yellow Freight Sys., Inc., 785 N.E.2d 501 (Ohio Ct. App. 2003). “II ASSIGNMENT OF ERROR {¶ 6} “The trial court erred when it granted summary judgment against United Parcel Service, and concluded that R.C. 4123.93 was unconstitutional.” {¶ 7} In its sole assignment of error, appellant asserts that the trial court erred when it granted summary…”
— Ohio Rev. Code § 4123.93(E) — 5 cases
Groch v. Gen. Motors Corp., 117 Ohio St. 3d 192 (Ohio 2008). “For the reasons that follow, we answer the certified questions by holding that R.C. 4123.93, 4123.931, 2305.10(C), and former 2305.”
Ohio Bureau of Workers' Comp. v. McKinley, 2011 Ohio 4432 (Ohio 2011). “1 {¶ 6} On November 4, 2008, the bureau filed suit in Columbiana County Common Pleas Court against McKinley and Heritage, asserting that they were jointly and severally liable under R.C. 4123.93 and 4123.931 for failing to honor the bureau’s subrogation lien in the settlement…”
Thomas v. Logue, 2023 Ohio 3522 (Ohio 2023). “{¶ 27} The phrase “on behalf of” is not defined by R.C. 4123.93. “When a term is undefined, we give the term its ‘plain and ordinary meaning.”
Smith v. Jones, 889 N.E.2d 141 (Ohio Ct. App. 2007). “Additionally, Smith alleged that the workers’ compensation subrogation statutes, R.C. 4123.93 and 4123.931, were unconstitutional on their face and as applied to her, and she requested a declaratory judgment.”
McKinney v. Omni Die Casting, Inc., 2017 Ohio 2949 (Ohio Ct. App. 2017). “The BWC argued R.C. 4123.93 and R.C. 4123.931 create an independent right of recovery in favor of a statutory subrogee, here, the BWC, against a third party who may be liable to McKinney for his injuries.”
— Ohio Rev. Code § 4123.93(F) — 4 cases
Groch v. Gen. Motors Corp., 117 Ohio St. 3d 192 (Ohio 2008). “For the reasons that follow, we answer the certified questions by holding that R.C. 4123.93, 4123.931, 2305.10(C), and former 2305.”
Thomas v. Logue, 2023 Ohio 3522 (Ohio 2023). “{¶ 27} The phrase “on behalf of” is not defined by R.C. 4123.93. “When a term is undefined, we give the term its ‘plain and ordinary meaning.”
Figley v. Ivex Prot. Packaging, Inc., 2016 Ohio 3501 (Ohio Ct. App. 2016).
Smith v. Jones, 889 N.E.2d 141 (Ohio Ct. App. 2007). “Additionally, Smith alleged that the workers’ compensation subrogation statutes, R.C. 4123.93 and 4123.931, were unconstitutional on their face and as applied to her, and she requested a declaratory judgment.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.