Previous Version of Subrogation Statute Declared Unconstitutional
Modzelewski v. Yellow Freight Systems, Inc. (2/26/03), Summit App. No. 21205, 2003-Ohio-827.
In this case another Court of Appeals found that the version of R.C. §4123.93, the subrogation statute which existed before the subrogation statute declared unconstitutional by the Supreme Court in Holeton v. Crouse Cartage Co. (2001), 92 Ohio St.3d 115, is also unconstitutional.
Previous decisions declaring the former R.C. § 4123.93 subrogation statute unconstitutional include: