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2092 An employer or workers' compensation carrier that has paid benefits to an employee is entitled to full reimbursement from the proceeds of the employee's action against third parties who were responsible for the injury, without regard to whether the employee has been made whole; but the employer or carrier is not entitled to reimbursement from the proceeds of a loss of consortium action brought by the employee's spouse.CitationGAPUSAN v JAY (Employer Reimbursement) 66 CA4 734 [See: LabC 3860; Sea-Land v WCAB 14 C4 76; O'Dell v Freightliner 10 CA4 645, T/AT 12/92; Sapiano v Williamsburg 28 CA4 533; United v Kelly 140 CA3 72; Security v Hand 31 CA3 227]CASE
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