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The made whole doctrine as well as the basic principles of subrogation emphasize the loss suffered by the insured. (Shutterstock) The made whole doctrine as well as the basic principles of subrogation emphasize the loss suffered by the insured. (Shutterstock)

The Supreme Court of Washington has ruled that a first-party insurer, upon obtaining a partial recovery in a subrogation action, must reimburse its fault-free insureds for the full amount of their deductibles before any portion of the subrogation proceeds can be allocated to the insurer.

Steven A. Meyerowitz

Steven A. Meyerowitz, a Harvard Law School graduate, is the founder and president of Meyerowitz Communications Inc., a law firm marketing communications consulting company. Mr. Meyerowitz is the Director of the Insurance Coverage Law Center and editor-in-chief of journals on insurance law, banking law, bankruptcy law, energy law, government contracting law, and privacy and cybersecurity law, among other subjects. He may be contacted at smeyerowitz@meyerowitzcommunications.com.

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