The Alabama Insurance Guaranty Association ("AIGA") filed an action against Mercy Medical Association, and Catholic Health East, Inc. ("CHE"), seeking to recover money it had paid on behalf of Mercy Medical and CHE on workers' compensation claims filed by employees of Mercy Medical as well as a judgment declaring its right to reimbursement of statutory benefits to be paid on the employees' claims in the future. AIGA, Mercy Medical, and CHE each moved for a summary judgment. The trial court entered a summary judgment in favor of Mercy Medical and CHE, determining: (1) that the 2000 AIGA Act applied because it was in effect at the time of the insolvency of Reliance National Insurance Company (CHE's workers' compensation insurer), and at the time the workers' compensation judgment was entered against Mercy Medical; (2) that the 2009 AIGA Act did not apply retroactively because the 2009 amendments to the AIGA Act substantively changed the law; and (3) that under the 2000 AIGA Act, Mercy Medical's net worth did not exceed $25,000,000, so AIGA could not recover any amounts it had paid on behalf of Mercy Medical. AIGA appealed. Upon review, the Supreme Court concluded that the applicable law governing the vesting of AIGA's right to reimbursement of claims paid was the law in effect on the date of the insurer's insolvency. Further, the Court also concluded that the addition of the net-worth definitions in the 2009 AIGA Act were substantive and did not apply retroactively in this case. Finally, the Court concluded that AIGA was not entitled to reimbursement from Mercy Medical or CHE because, under the 2000 AIGA Act, Mercy Medical's net worth did not exceed
$25,000,000 and the payments were not made on behalf of CHE. Accordingly, the Court affirmed the trial court's judgment in favor of Mercy Medical and CHE. View "Alabama Insurance Guaranty Association v. Mercy Medical Association" on Justia Law
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