Connecticut Clarifies Made Whole Risk In Auto Subrogation: Orlando v. Liburd, 2026 WL 41344 (Conn. Jan. 6, 2026)
The ongoing assault against subrogation continues. The Connecticut Supreme Court’s January 6th decision in Orlando v. Liburd, should be treated as a practical warning for carriers and subrogation professionals pursuing automobile physical damage recoveries in Connecticut.[1] It instructs us that, unless the policy expressly and effectively disclaims the Made Whole Doctrine as a limitation on…