Pennsylvania Manufacturers' Association Insurance Company v. Wolfe

In Pennsylvania Manufacturers' Association Insurance Company v. Wolfe, 534 Pa. 68, 626 A.2d 522 (1993), the Court determined that the attorney who creates the third-party settlement fund is entitled to get paid prior to the insurer's receiving any benefit from that settlement, noting that "but for the attorney's actions, there would be no fund for either the workers' compensation carrier or for the client-injured employee." Id. at 74, 626 A.2d at 525.