It is not uncommon for injured persons to assign their rights to insurance proceeds to a third party, and the enforceability of those assignments has been the subject of frequent litigation around the country. In the most recent development on this topic, Allstate Ins. Co. v. Medical Lien Mgmt., 2015 CO 32, 2015 WL 3378141, 2015 Colo. LEXIS 447 (Colo., May 26, 2015), the Colorado Supreme Court held that an injured person’s assignment to a medical lien company was not enforceable against the insurance company. In Allstate, an individual, Martinez, was injured in a car accident with Allstate’s insured. Martinez entered into an agreement with Medical Lien Management (MLM) in which MLM agreed to pay for Martinez’s medical treatment in…