Until the Pennsylvania Supreme Court's 2018 decision in Whitmoyer v. Workers' Compensation Appeals Board (Mountain Country Meats), an employer's right to subrogation under Section 319 of the Workers' Compensation Act has repeatedly been found by the courts to be absolute, with few exceptions. Certainly, where the injured worker recovers from an uninsured motorist policy that he paid for himself, or to the extent workers' compensation benefits are paid pursuant to the Heart and Lung Act, no subrogation by the employer is available. There was a time when the Pennsylvania Commonwealth Court's recognition that Heart and Lung Act benefits do not violate the principles of double recovery that the concept of "other" noneconomic damages being excluded from subrogation was foreseeable. Specifically, pain and suffering damages, which are clearly a component of workers' compensation damages, remain inexplicably subject to subrogation. While that seeming injustice remains unaltered, Whitmoyer has had the effect of pushing back on universal and absolute subrogation in other ways.