Workers Compensation Fund v. Utah Business Insurance Company

Summary

The Utah Supreme Court held that the targeted tender doctrine is incompatible with Utah’s statutory workers compensation scheme. Because both insurers’ policies covered the employee’s injury, both were jointly liable, and Workers Compensation Fund was entitled to equitable contribution from Utah Business Insurance Company for reasonable past and future claim costs. The court affirmed the denial of summary judgment and additional discovery and remanded for resolution of remaining issues.

Holdings

1. The targeted tender doctrine is incompatible with Utah's workers compensation statutory scheme and does not apply in the workers compensation context.
2. Because both policies covered the injury and the targeted tender doctrine does not apply, UBIC and WCF were jointly liable for Antone's claim. WCF was entitled to equitable contribution from UBIC for one-half of the reasonable past and future benefits paid on the claim.
3. The district court did not abuse its discretion in denying UBIC's Rule 56(f) motion for additional discovery.

Questions Presented

1. Whether Utah's workers compensation statutory scheme permits application of the targeted tender doctrine when multiple insurers cover the same workplace injury.
2. Whether UBIC and WCF were jointly liable for Antone's claim and whether WCF was entitled to equitable contribution from UBIC.
3. Whether the district court abused its discretion by denying UBIC's motion for additional discovery under Utah Rule of Civil Procedure 56(f).

Disposition

affirmed