The case of Goyco v. Progressive Insurance, A-12-23, decided on May 14, reminds us that even narrow issues can attract the court's attention if not previously interpreted by an appellate court. The proposition at issue is one.

A "pedestrian" as defined in N.J.S.A. 39:6A-2(a) is any person who is injured while occupying, entering into, or alighting from a vehicle (a) propelled by other than muscular power and (b) designed primarily for use on highways, rails or tracks. Mandatory PIP coverage in motor vehicle policies must be provided if the injured person matches that definition in the statute. Motorcycle riders do not qualify for PIP benefits because motorcycles are not automobiles. N.J.S.A. 39:1-1. Bicyclists are deemed "pedestrians," although bicycles are propelled by muscle power, because the Legislature wanted to give bicyclists PIP coverage. On the other hand, operators of mopeds, although peddled for the purpose of engaging the motor, are not pedestrians. N.J.S.A. 39:6A-2(h).