Section 27-2-102, MCA
 State Fund v. Lowell McMillan [10/25/99] 1999 MTWCC 64 Section 39-71-414, MCA (1985) creates a statutory lien against monies received by claimant. The two-year statute of limitations specified by section 27-2-211(1), MCA, applies. Under section 39-71-414, MCA, the two-year statute starts running from the "claim, judgment, or recovery" of a claimant, which means that actual receipt of monies due under a judgment (i.e., "recovery") triggers a renewal of the statutory lien and commencement of a two-year limitations period. Where the action is timely under the appropriate limitations period, the claimant must show "extraordinary circumstances" to invoke the doctrine of laches. [Note: The WCC issued an order granting summary judgment to claimant on a separate issue, reported at 2000 MTWCC 42. As of 6/13/01, that order was on appeal to the Montana Supreme Court.] See also, Royal Insurance Company v. Roadarmel, 2000 MT 259, in which the Supreme Court concluded that an insurer's "first lien" under section 39-71-414(1), MCA (1985), against any proceeds in a third-party action constitutes a "liability created by statute" governed by the two-year limitation period of section 27-2-211(1)(c), MCA.