Cundiff v. State Farm: Allowing Double Recovery Under UIM and Workers’ Compensation

In Cundiff v. State Farm Mutual Automobile Insurance Co., the Arizona Supreme Court unanimously held that an insurer may not reduce Underinsured Motorist (“UIM”) coverage by the amount of workers’ compensation benefits received by an insured. The court’s ultimate outcome is consistent with the majority of other jurisdictions that have addressed the issue of workers’ compensation offset provisions.