jury’s allocation of fault to TEP because the Webers failed to obtain TEP’s consent to the settlement. In rejecting this argument, the trial court noted that § 23-1023(0 provides that a carrier must approve any compromise of a claim for an amount “less than the compensation and medical, surgical and hospital benefits provided”; that the Webers had settled with Pingree for $950,000; and that TEP’s lien and future credit totaled $496,000, an amount “significantly less” than the settlement. Because it is undisputed that TEP paid William approximately $65,000 in benefits and because TEP did not produce any evidence or argue that its future credit might exceed $496,000, we find no error in the trial court’s ruling. Cf. Stout v. State Compensation Fund, 202 Ariz. 300, 44 P.3d 178 (App.2002) (<HOLDING>). ¶ 13 Accordingly, we affirm the trial court’s
holding that a city could not use past conduct to enjoin future protected speech holding that employers insurer who provided workers compensation benefits to employee but did not consent to employees settlement with thirdparty tortfeasor may maintain an action for payments that become payable in the future holding that debtor was liable to the commonwealth for past and future cleanup costs holding that prejudgment interest may properly be added to damage awards for past lost wages medical expenses that have been incurred and past pain and suffering but not future loss of earnings future medical expenses andor future pain and suffering holding that carriers consent required if past and future benefits might exceed settlement