A few days ago, the Pennsylvania Supreme Court weighed in on the latest of the seemingly never-ending mutations of an employer's "absolute" right to subrogation under Section 319 of the Workers' Compensation Act. Few and far between are the instances where subrogation can be thwarted. Before the court, in somehow a matter of first impression, was presented the propriety of an insurer actually attempting to seek subrogation against its own insured.  Historically, the law has generally supported a equitable prohibition against such a practice. Of course, history has never met Section 319 of the act!