Insurer's Right to Reimbursement and the Anti-Subrogation Rule

In an unpublished decision issued today, Division One of the Washington Court of Appeals held that policy language authorizing an insurer to be reimbursed for property damage payments from the proceeds of a settlement its insured obtained from a third party tortfeasor insured by the same carrier did not trigger the anti-subrogation rule because the carrier was claiming a right to reimbursement, not a right to proceed directly against the third party. Horner v. Farmers Ins Co., No. 64169-7.