Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Fifth Circuit: McGill Parfait v. DOWCP, et al
Lack of notification of award from third party was a jurisdictional bar to any award of funds, given the statute; the purpose of the award is to prevent double recoveries.