How have courts interpreted the doctrine of equitable apportionment in the worker's compensation context?

Another case, Steinberg v. Allstate Ins. Co., supra, 226 Cal.App.3d 216, 277 Cal.Rptr. 32, applied the doctrine of equitable apportionment outside the worker's compensation context. In Steinberg, homeowners filed suit after landslides damaged their homes. The suits included claims against several homeowners' insurance carriers. One of the insurers ultimately settled the claims brought by its insureds. As a result of its payments, the insurer had a subrogation claim against the third party tortfeasors. (Id. at p. 219, 277 Cal.Rptr. 32.) The insurer retained a law firm to pursue its subrogation rights and agreed to pay the firm 25% of any amount recovered.