Cozzone v. Garda GL Great Lakes, Inc.

Regardless of when an employer waives its workers' compensation lien, its contribution liability is always capped at the same amount.  Where employer's liability for contribution was determined by verdict after Plaintiff settled with underlying Defendants and received assignment of Defendants' contribution claims against employer, the employer's maximum contribution liability is still limited to amount of its workers' compensation obligation.(HOFFMAN and HALL, concurring.)