Justices to Decide If Injured Motorists Can Recoup Benefits Beyond PIP Limits
The New Jersey Supreme Court has taken up a case that requires it to consider whether motorists who opt for the $15,000 minimum in personal-injury-protection benefits in their insurance policies can recover medical expenses exceeding that amount.
November 15, 2017 at 05:05 PM
10 minute read
The New Jersey Supreme Court has taken up a case that requires it to consider whether motorists who opt for the $15,000 minimum in personal-injury-protection benefits in their insurance policies can recover medical expenses exceeding that amount.
The court on Tuesday granted a petition for certification agreeing to hear the two consolidated cases: Haines v. Taft and Little v. Nishimura.
The court will likely hold oral arguments in the cases next year.
In June, a three-judge Appellate Division panel, in a reported decision, said plaintiffs in automobile accident cases that choose the PIP minimum may recover medical expenses that exceed $15,000. Judge Amy O'Connor, joined by Judges Hany Mawla and Marie Lihotz, said statutes limiting PIP recovery apply only to co-payments and deductibles.
“We are satisfied the language references the litigation of minor medical expenses, such as co-payments and deductibles … not all medical expenses,” O'Connor said.
In the ruling, the appeals court overturned decisions by two Camden County Superior Court judges to bar the admission of evidence from two injured motorists, Joshua Haines and Tuwona Little, who were covered by policies that included the $15,000 PIP limit, but whose medical expenses were greater. Both plaintiffs appealed the trial court rulings.
The Insurance Council of New Jersey and the New Jersey Defense Association contested the appeals as amici, arguing that the Legislature, in various statutes enacted over recent years, sought to limit plaintiffs' recovery for medical expenses based on the PIP options they chose in their policies.
“We decline to adopt this inferential determination,” O'Connor wrote in June.
Haines and Little were injured in separate automobile accidents, according to the decision.
Haines, after his PIP benefits were exhausted and after paying his co-payment and deductible, still had $28,000 in uncovered medical expenses. Little, after her benefits were exhausted, had $10,488 in unpaid medical expenses, the court said.
O'Connor said the relevant PIP and automobile insurance statutes permit them to seek recovery for those unpaid medical expenses—co-pays and deductibles, she added, are different from other medical expenses.
O'Connor noted that the Legislature permitted drivers to choose PIP limits of $15,000, $50,000, $75,000 or $150,000 in order to limit premiums. The Legislature did not, however, include language that limited recovery for medical expenses that exceeded co-payments and deductibles, she said.
“Having the right to recover a claim against a tortfeasor for medical expenses not covered by PIP does not result in a windfall for those who, in exchange for reduced PIP benefits, paid lower premiums,” O'Connor said.
O'Connor quoted a 2011 Law Division ruling in Wise v. Marienski: “Plaintiffs are not having their cake and eating it, too. Their medical expenses are not immediately recoverable. Instead, they must file suit, go through the discovery process, and run the gauntlet of proving defendant's liability. That process typically takes years.”
The NJDA's attorney, Stephen Foley Jr., said it was “appropriate” that the Supreme Court take up the question.
“This is a question the court needs to answer,” said Foley, of Campbell, Foley, Delano & Adams in Asbury Park.
The defendants, Jacob Taft and Jayne Nishimura, are represented by Michael Marone of Morristown's McElroy, Deutsch, Mulvaney & Carpenter. Susan Stryker of Bressler, Amery & Ross in Florham Park represents the ICNJ. The plaintiffs are represented by Vincent Campo of Malamut & Associates in Cherry Hill.
None returned calls about the court's certification grant.
The New Jersey Supreme Court has taken up a case that requires it to consider whether motorists who opt for the $15,000 minimum in personal-injury-protection benefits in their insurance policies can recover medical expenses exceeding that amount.
The court on Tuesday granted a petition for certification agreeing to hear the two consolidated cases: Haines v. Taft and Little v. Nishimura.
The court will likely hold oral arguments in the cases next year.
In June, a three-judge Appellate Division panel, in a reported decision, said plaintiffs in automobile accident cases that choose the PIP minimum may recover medical expenses that exceed $15,000. Judge
“We are satisfied the language references the litigation of minor medical expenses, such as co-payments and deductibles … not all medical expenses,” O'Connor said.
In the ruling, the appeals court overturned decisions by two Camden County Superior Court judges to bar the admission of evidence from two injured motorists, Joshua Haines and Tuwona Little, who were covered by policies that included the $15,000 PIP limit, but whose medical expenses were greater. Both plaintiffs appealed the trial court rulings.
The Insurance Council of New Jersey and the New Jersey Defense Association contested the appeals as amici, arguing that the Legislature, in various statutes enacted over recent years, sought to limit plaintiffs' recovery for medical expenses based on the PIP options they chose in their policies.
“We decline to adopt this inferential determination,” O'Connor wrote in June.
Haines and Little were injured in separate automobile accidents, according to the decision.
Haines, after his PIP benefits were exhausted and after paying his co-payment and deductible, still had $28,000 in uncovered medical expenses. Little, after her benefits were exhausted, had $10,488 in unpaid medical expenses, the court said.
O'Connor said the relevant PIP and automobile insurance statutes permit them to seek recovery for those unpaid medical expenses—co-pays and deductibles, she added, are different from other medical expenses.
O'Connor noted that the Legislature permitted drivers to choose PIP limits of $15,000, $50,000, $75,000 or $150,000 in order to limit premiums. The Legislature did not, however, include language that limited recovery for medical expenses that exceeded co-payments and deductibles, she said.
“Having the right to recover a claim against a tortfeasor for medical expenses not covered by PIP does not result in a windfall for those who, in exchange for reduced PIP benefits, paid lower premiums,” O'Connor said.
O'Connor quoted a 2011 Law Division ruling in Wise v. Marienski: “Plaintiffs are not having their cake and eating it, too. Their medical expenses are not immediately recoverable. Instead, they must file suit, go through the discovery process, and run the gauntlet of proving defendant's liability. That process typically takes years.”
The NJDA's attorney, Stephen Foley Jr., said it was “appropriate” that the Supreme Court take up the question.
“This is a question the court needs to answer,” said Foley, of Campbell, Foley, Delano & Adams in Asbury Park.
The defendants, Jacob Taft and Jayne Nishimura, are represented by Michael Marone of Morristown's
None returned calls about the court's certification grant.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllHit by Mail Truck: Man Agrees to $1.85M Settlement for Spinal Injuries
Appellate Div. Follows Fed Reasoning on Recusal for Legislator-Turned-Judge
4 minute readChiesa Shahinian Bolsters Corporate Practice With 5 From Newark Boutique
5 minute readOn the Move and After Hours: Brach Eichler; Cooper Levenson; Marshall Dennehey; Archer; Sills Cummis
7 minute readTrending Stories
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250