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On Dec. 21, 2011, in Jones v. Nationwide Property and Casualty Ins. Co. ,32 A.3d 1261 (Pa. 2011), the Pennsylvania Supreme Court addressed the applicability of the “made-whole doctrine” to subrogation cases involving collision coverage for automobiles. In short, the made-whole doctrine is a common law application of equitable principles that provides an insurance company may not exercise its right of subrogation until its insured receives full compensation for the underlying loss. The Supreme Court held that the made-whole doctrine does not apply to the collision coverage at issue and affirmed the dismissal of the case.

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