Montana’s Made Whole Maze: Navigating Subrogation After Johnson and Smith
For nearly fifty years, Montana has been ground zero for the aggressive application of the Made Whole Doctrine. Intimidation, bad-faith actions, and class action lawsuits have littered the ground where common-sense insurance subrogation used to dwell. What began as an equitable principle established by the Montana Supreme Court in 1977 in Skauge v. Mountain States…