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  • About
  • Our Team
    • Attorneys
    • Paralegals & Claims Specialists
    • Administration
    • Support Staff
  • Practice Areas
    • Nationwide Insurance Subrogation
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    • Insurance Coverage
    • Mediation Services
  • Resources
    • Podcasts
    • Newsletters
    • Laws By State
    • Published Articles
    • MWL Published Books
      • Automobile Insurance Subrogation In All 50 States
      • Fundamentals of Insurance Coverage In All 50 States
      • Workers’ Compensation Subrogation In All 50 States
      • ERISA and Health Insurance Subrogation in All 50 States
      • “Where’s The Beef?” Subrogating Livestock/Vehicle Collisions In All 50 States
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Subro Win

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Montana Supreme Court Narrows the Made-Whole Doctrine

Newsletter, SubrogationBy Payton WhiteNovember 14, 2025

Montana’s Harsh History with the Made-Whole Doctrine For decades, Montana has been recognized as perhaps the harshest jurisdiction in the country when it comes to the application of the “Made-Whole” doctrine in subrogation cases. And it stands to reason that the harsh application of this anti-subrogation rule has led to depleted subrogation opportunities and has…

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