[1995] Lockart v. New Hampshire Insurance Company and Liberty Northwest v. Petak, 1999 MT 205 The attorneys fee lien codified at section 37-61-420, MCA, applies to medical benefits recovered due to the efforts of the attorney in a workers' compensation claim. This follows from the conclusion that medical benefits are compensation benefits within the WCA. Attorneys fees under an attorney retainer agreement approved by the DOL are thus recoverable from the medical benefits otherwise payable directly to medical providers.

[1995] Lockart v. New Hampshire Insurance Company and Liberty Northwest v. Petak [7/31/98] 1998 MTWCC 60 Consolidated cases raised the issue whether claimants' attorneys are entitled to attorney fees with regard to medical benefits secured with their efforts paid out of medical benefits. WCC held attorneys are not entitled to satisfy their fee liens from medical benefits secured on behalf of clients. [Note: WCC reversed on this issue in Lockart v. New Hampshire Insurance Company and Liberty Northwest v. Petak, 1999 MT 205.]