Emanuel v. Montana State Fund [05/01/15] 2015 MTWCC 8 In an action between an injured worker and State Fund under § 39-71-405(1), MCA, the UEF is not a proper third party; if the injured worker prevails, State Fund can only seek indemnification from the uninsured contractor. Furthermore, the statute of limitations for an appeal of the UEF’s denial of liability has run, and the Court therefore lacks jurisdiction over the UEF.  The UEF consequently has no stake in the outcome of the case.