Secura Supreme Insurance Company v. The Estate of Daniel Keith Huck, 986 N.W.2d 810

Daniel Huck was killed in the scope of his employment; his Estate first received $35,798.04 in worker's compensation (WC) benefits and later a $25,000 tortfeasor settlement.
Under Wis. Stat. §102.29 the Estate had to reimburse the WC insurer $9,718.73 of the tort settlement, leaving the Estate with net WC of $26,079.31.
Huck's Secura UIM policy had a $250,000 per-person limit and a reducing clause allowing setoffs for (a) amounts paid by tortfeasors and (b) amounts paid or payable under workers' compensation law.
Secura reduced its UIM payment by $25,000 (tort settlement) and by the full $35,798.04 WC payment and tendered $189,201.96; the Estate sought the $9,718.73 reimbursement back.
The circuit court and court of appeals ruled for the Estate; the Wisconsin Supreme Court affirmed, holding Secura must pay the $9,718.73 because reductions are calculated based on the insured's recovery after statutory WC reimbursements.

Issue	Plaintiff's Argument (Secura)	Defendant's Argument (Estate)	Held
Whether Secura's policy permits reducing UIM limits by the gross WC payment even though part was statutorily reimbursed	"Paid" means the WC carrier and tortfeasor discharged obligations when they paid the Estate, so Secura may deduct the full amounts initially paid	The policy contemplates WC payments made "in accordance with" WC law; reductions must account for statutorily required reimbursements, i.e., the insured's net recovery	Court: Policy requires Secura to calculate reductions after final resolution (including §102.29 reimbursements); Secura may not deduct the reimbursed $9,718.73.
Whether Wis. Stat. §632.32(5)(i) authorizes reducing UIM limits by amounts initially paid even if later reimbursed under WC law	The statute permits reduction by "amounts paid" (or "paid or payable") without regard to subsequent reimbursements	The statute contemplates WC law (including §102.29); "amounts paid" refers to the insured's final/outstanding recovery when the insurer enforces the reducing clause	Court: §632.32(5)(i) is read to allow reduction by amounts paid/payable as measured at the time the insurer enforces the clause (i.e., the insured's final recovery); Secura may not reduce by sums the insured was obligated to repay.

Teschendorf v. State Farm Ins. Cos., 293 Wis. 2d 123, 717 N.W.2d 258 (Wis. 2006) (addressed limits on reducing clauses; central precedent discussed)
State ex rel. Kalal v. Circuit Court for Dane County, 271 Wis. 2d 633, 681 N.W.2d 110 (Wis. 2004) (statutory interpretation principles)
Smith v. Atlantic Mutual Ins. Co., 155 Wis. 2d 808, 456 N.W.2d 597 (Wis. 1990) (insurance-policy interpretation follows contract principles)
Welin v. American Family Mutual Ins. Co., 292 Wis. 2d 73, 717 N.W.2d 690 (Wis. 2006) (describing UIM coverage as a predetermined, fixed level combined from multiple sources)
Dowhower ex rel. Rosenberg v. Western Bend Mutual Ins. Co., 236 Wis. 2d 113, 613 N.W.2d 557 (Wis. 2000) (explaining reducing-clause mechanics)