No Free Ride on Future Benefits: Utah Requires Workers’ Compensation Carriers to Pay For The Future Credit They Claim (HB Construction v. Labor Comm’n of Utah, 2026 WL 534446 (Utah 2026))
The Utah Supreme Court has issued an important decision for workers’ compensation and subrogation professionals navigating third-party recoveries and future credits. In HB Construction and/or Auto Owners Insurance Co. v. Labor Commission of Utah, the Court resolved a long-standing ambiguity in Utah Code § 34A-2-106(5) and clarified how attorney fees must be allocated when a…