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Scott Cooper
Scott Cooper
Attorney • (800) 232-6301

Pennsylvania Supreme Court Holds Made Whole Doctrine Does Not Apply To Collision Coverage Deductible

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The Pennsylvania Supreme Court yesterday in Jones v. Nationwide rendered an opinion regarding insurance coverage and recovery of deductibles. This case involves the challenge of the insurance company practice of reimbursing, on a pro rata basis only, an insured’s deductible from funds obtained in an insurer’s subrogation against a third party tortfeasor. The Court concludes that the made whole doctrine does not apply to the collision coverage and the pro rata reimbursement is allowable.


Scott B. Cooper
Schmidt Kramer PC
209 State Street
Harrisburg, PA 17101
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