Pacific Indemnity Insurance Company v. Liberty Mutual Insurance Company and Vidal Lopez
Pacific Indemnity Insurance, a workers' compensation carrier, sued Liberty Mutual Insurance for reimbursement in district court without first exhausting administrative remedies with the Industrial Accident Board (IAB). This lawsuit stemmed from a worker's injury in 1984 and subsequent re-injury in 1988. Pacific Indemnity, the carrier for the initial injury, continued to pay benefits after the re-injury and sought reimbursement from Liberty Mutual, the subsequent carrier, which was denied. The IAB issued orders regarding payments but did not address the reimbursement claim. The district court granted summary judgment for Liberty Mutual, a decision upheld on appeal because Pacific Indemnity failed to obtain an IAB ruling on the reimbursement issue before filing suit, thereby lacking jurisdiction in district court. The failure to exhaust administrative remedies bars the suit as a matter of law.