dissenting.
Instantly, this court is required to determine whether the laws of this state or New Jersey apply to an action initiated by the plaintiff-employee to recover damages for injuries allegedly caused by third-party tortfeasors. Specifically, we must determine whether the right of subrogation provided for by the New Jersey Workers’ Compensation Act or the prohibition against subrogation set forth in the Pennsylvania Motor Vehicle Financial Responsibility Law (MVFRL), 75 Pa.C.S.A. § 1701 et seq., applies to the instant dispute. To resolve this question, we must analyze the policies and *152interests that underlie the dispute and then determine which state has the greatest interest in having its law applied to the case. Griffith, supra. Although the majority has conducted such an analysis, I find that its decision is contrary to Pennsylvania law and therefore, I must respectfully dissent.
Under New Jersey law, an employer is subrogated to any monies recovered by its employee from a third-party tortfeasor who is legally responsible for the employee’s injury. N.J.S.A. 34:15-40. The reason New Jersey allows subrogation is to guarantee that an injured employee receives only a single recovery for his injuries. Lefkin v. Venturini, 229 N.J.Super. 1, 550 A.2d 985 (1988).
When an employee is injured in a work-related motor vehicle accident, the employee could theoretically seek reimbursement for his economic injuries from his employer, a motor vehicle insurance policy or by bringing a civil action against the tortfeasor. New Jersey addresses this factual situation via a reimbursement scheme which precludes recovery under the motor vehicle insurance policy and allows the plaintiff-employee to seek a full recovery from the third-party tortfeasor subject only to the workers’ compensation lien of the employer. Lefkin, supra. Thus, the employee is compensated for his injuries, but by way of a single recovery.
Under Pennsylvania law, an injured employee is also limited to a single recovery. However, our compensation scheme differs significantly from the system adopted by New Jersey.
In Pennsylvania, our legislature has put into place a compensation scheme which requires that workers’ compensation and motor vehicle insurers bear the primary burden of providing compensation for economic loss. 75 Pa.C.S.A. § 1722. Therefore, the plaintiff-employee can seek compensation from the tortfeasor only for such injuries not recoverable under workers’ compensation or by the provisions of the MVFRL. Id. Thus, the workers’ compensation insurer’s statutory right of subrogation has been abrogated to *153assure a full recovery for an injured employee. 75 Pa. C.S.A. § 1720. Compare 77 P.S. § 671 (employer subrogated to rights of employee when injury caused by a third party).
From the above discussion, it is apparent that the policy of both compensation schemes is to allow the plaintiff-employee a full but single recovery. Therefore, a conflict does not exist with regard to appellant’s right to subrogation. Rather, the true conflict before us is who should bear primary responsibility for the economic losses suffered by the plaintiff-employee; the New Jersey employer or the Pennsylvania tortfeasors.1
Here, the plaintiff-employee, as well as the tortfeasors, are Pennsylvania residents. Pennsylvania is also the situs of the accident. The only connection this case has with New Jersey arises from the plaintiff-employee’s decision to assert a workers’ compensation claim under New Jersey law. Under these facts, I fail to understand how this court can find that New Jersey’s interest in allowing a full recovery from a tortfeasor can prevail over our interest in limiting the recovery available from third-party tortfeasors. Therefore, I would deny appellant’s petition to intervene.
In reaching this decision, I am mindful of this court’s decisions in Van Den Heuval, supra and Myers, supra which allowed an out-of-state workers’ compensation carrier to intervene in a suit brought in this state to recover for injuries incurred during an automobile accident. Although this court allowed the carriers to intervene, the result reached in each case is specific to the facts of that case. Neither case stands for the broad proposition that an out-of-state workers’ compensation insurer has an absolute right *154to intervene in a Pennsylvania civil action. To the contrary, these cases require that we analyze the interests of the foreign workers’ compensation law, our own state’s interest in the dispute and then determine which law is applicable to the facts before us. Thus, I do not feel constrained to follow the result reached in either Van Den Heuval or Myers2
Accordingly, I would affirm the order of the trial court denying appellant’s petition to intervene.
. The majority does not address this pivotal issue, but focuses its discussion on appellant’s right of subrogation and the plaintiff-employee’s right to be fully compensated for his injuries. What they do not consider is the impact their decision will have on the tortfeasors. The majority requires that the tortfeasors bear the burden of providing the plaintiff a full recovery. Not only is this result not dictated by Pennsylvania’s choice-of-law standard, it directly contravenes the express mandates of the MVFRL. 75 Pa.C.S.A. § 1722.
. I agree with the holdings of these cases which recognize the interest that our sister states have in administering their workers’ compensation system. However, I feel that this court must also keep in mind that the purpose of the MVFRL is to ensure that injured parties are afforded a complete recovery for their losses. Walters v. Kamppi, 118 Pa.Commw. 487, 545 A.2d 975 (1988), alloc. denied, 520 Pa. 622, 554 A.2d 513 (1989).