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December 23, 2020

Mollo Chiropractic, PLLC v American Commerce Ins. Co. (2020 NY Slip Op 51548(U))

https://www.beynensonlaw.com/case-law/mollo-chiropractic-pllc-v-american-commerce-ins-co-2020-ny-slip-op51548u/

Court
Appellate Term, Second Department
Decided
December 23, 2020
Citation
2020 NY Slip Op 51548(U)
Posture
Trial
Outcome
Insurer prevailed
Issues
Medical necessity Trial and evidence
Legal questions
Lack of medical necessity (see the maps)
Cite as
Mollo Chiropractic, PLLC v American Commerce Ins. Co., 2020 NY Slip Op 51548(U) (App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2020)

Posture, outcome, issues and treatment by other decisions are Beynenson Law’s classification. Treatment labels are assigned by a language model reading the citing decision; negative and appeal-history labels are checked by a second reader.

Summary

Editorial summary by Beynenson Law, not part of the court’s decision.

The insurer's expert supplied a factual basis and medical rationale for finding manipulation under anesthesia medically unnecessary. After a consolidated nonjury trial of two no-fault actions, the Appellate Term, Second Department, affirmed both judgments dismissing the provider's complaints. The expert's trial testimony remained within the peer review report's theory: the treatment should be used rarely, and inconsistent records did not establish that these cases warranted it. Deferring to credibility findings, the appellate court sustained the trial court's decision to credit that testimony over the provider's witness. Any error in excluding questions about a textbook not in evidence was harmless under CPLR 2002 because the provider identified no resulting prejudice.

Reported in New York Official Reports at Mollo Chiropractic, PLLC v American Commerce Ins. Co. (2020 NY Slip Op 51548(U))

SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT, 2d, 11th and 13th JUDICIAL DISTRICTS

Mollo Chiropractic, PLLC, as Assignee of Jason Solas, Appellant,

against

American Commerce Insurance Company, Respondent.

Lower Court # 131906/09 The Rybak Firm, PLLC, (Damin J. Toell and Karina Barska of counsel), for appellant. Bruno, Gerbino. Soriano & Aitken, LLP, (Nathan M. Shapiro and Shaun Malone of counsel), for respondent.

Appeals from two judgments of the Civil Court of the City of New York, Kings County (Steven Z. Mostofsky, J.), entered December 5, 2017 and February 8, 2018, respectively. Each judgment, after a consolidated nonjury trial of the two above-captioned actions, dismissed the respective complaint.

ORDERED that, on the court’s own motion, the appeals are consolidated for the purposes of disposition; and it is further,

ORDERED that the judgments are affirmed, with $25 costs on each appeal.

In these two actions by a provider to recover assigned first-party no-fault benefits, plaintiff appeals from two judgments, each of which, after a consolidated nonjury trial, dismissed the respective complaint on the ground of lack of medical necessity.

In reviewing a determination made after a nonjury trial, the power of this court is as broad as that of the trial court, and this court may render the judgment it finds warranted by the facts, bearing in mind that the determination of a trier of fact as to issues of credibility is given substantial deference, as a trial court’s opportunity to observe and evaluate the testimony and demeanor of the witnesses affords it a better perspective from which to assess their credibility (see Northern Westchester Professional Park Assoc. v Town of Bedford, 60 NY2d 492, 499 [1983]; Hamilton v Blackwood, 85 AD3d 1116 [2011]; Zeltser v Sacerdote, 52 AD3d 824, 826 [2008]).

Here, as the court implicitly determined, defendant’s expert witness adequately provided a factual basis and medical rationale for his conclusion that there was no medical necessity for the services at issue in each case, manipulation under anesthesia (MUA). Contrary to plaintiff’s contentions, the court did not rely on any evidence provided by defendant’s expert that [*2]impermissibly went beyond the scope of the peer review report (see Radiology Today, P.C. v Geico Ins. Co., 58 Misc 3d 132[A], 2017 NY Slip Op 51768[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2017]; Park Slope Med. & Surgical Supply, Inc. v Progressive Ins. Co., 34 Misc 3d 154[A], 2012 NY Slip Op 50349[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2012]). Defendant’s experts’s theory in both his peer review report and at trial was, essentially, that MUA is an “aggressive” and possibly dangerous treatment and should therefore be used very rarely, limited to cases where, among other things, there has first been improvement with a course of traditional chiropractic care, and that the records here were inconsistent and not clear enough to show that this was one of those cases. The court was entitled to credit that testimony. The court also implicitly found that plaintiff’s witness’s testimony was less credible and failed to sufficiently rebut defendant’s expert’s testimony.

To the extent plaintiff argues that the Civil Court erred in sustaining objections to questions regarding an MUA textbook that was not in evidence, “since [plaintiff] failed to identify any prejudice which resulted from such alleged error, we conclude that the error, if any, was harmless” (Edwards v Nemet Motors, LLC, 60 Misc 3d 28, 31 [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2018]; see CPLR 2002; Parris v New York City Tr. Auth., 140 AD3d 938 [2016]). Plaintiff’s remaining contentions were either not raised in the Civil Court or lack merit.

Accordingly, the judgments are affirmed.

ALIOTTA, P.J., SIEGAL and TOUSSAINT, JJ., concur.


ENTER:
Paul Kenny
Chief Clerk
Decision Date: December 23, 2020

Legal questions

A question of no-fault law this decision rules on, from our Legal Questions pages. Bars count the decisions on the question by year and court, coloured by category; circles are this decision and the decisions on the question it cites or that cite it. Point at a bar or circle for details. The categories and summaries are Beynenson Law’s classification, made by a language model and checked by a second reading.

Lack of medical necessity

Open the full map

Did the insurer’s proof establish lack of medical necessity, and did the provider’s evidence rebut it?

This decision: Insurer's proof established lack of medical necessity and the provider failed to rebut it

Held the insurer's expert gave a factual basis and medical rationale for finding the MUA procedures unnecessary, stayed within his peer review, and was properly credited over the provider's less credible witness.

  • Appellate DivisionApp Div 9
  • Appellate TermApp Term 521
  • Trial courtsTrial 87
2022, Appellate Division: 2 decisions (2 Insurer's proof insufficient)2020, Appellate Division: 1 decision (1 Provider's rebuttal sufficient)2019, Appellate Division: 1 decision (1 Insurer's proof insufficient)2016, Appellate Division: 2 decisions (1 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2008, Appellate Division: 1 decision (1 Insurer's proof insufficient)2007, Appellate Division: 2 decisions (2 Insurer raised triable issue)2023, Appellate Term: 1 decision (1 Provider's rebuttal sufficient)2022, Appellate Term: 1 decision (1 Unrebutted, insurer prevails)2021, Appellate Term: 4 decisions (4 Unrebutted, insurer prevails)2020, Appellate Term: 5 decisions (1 Unrebutted, insurer prevails, 2 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 1 Trial error, new trial)2019, Appellate Term: 15 decisions (8 Unrebutted, insurer prevails, 4 Insurer's proof insufficient, 3 Trial error, new trial)2018, Appellate Term: 13 decisions (7 Unrebutted, insurer prevails, 2 Provider's rebuttal sufficient, 4 Trial error, new trial)2017, Appellate Term: 20 decisions (5 Unrebutted, insurer prevails, 7 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 7 Trial error, new trial)2016, Appellate Term: 28 decisions (16 Unrebutted, insurer prevails, 7 Provider's rebuttal sufficient, 3 Insurer raised triable issue, 2 Insurer's proof insufficient)2015, Appellate Term: 22 decisions (9 Unrebutted, insurer prevails, 9 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 2 Insurer's proof insufficient, 1 Trial error, new trial)2014, Appellate Term: 40 decisions (16 Unrebutted, insurer prevails, 22 Provider's rebuttal sufficient, 1 Insurer's proof insufficient, 1 Trial error, new trial)2013, Appellate Term: 57 decisions (40 Unrebutted, insurer prevails, 12 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 2 Insurer's proof insufficient, 2 Trial error, new trial)2012, Appellate Term: 76 decisions (54 Unrebutted, insurer prevails, 10 Provider's rebuttal sufficient, 2 Insurer raised triable issue, 5 Insurer's proof insufficient, 5 Trial error, new trial)2011, Appellate Term: 56 decisions (42 Unrebutted, insurer prevails, 6 Provider's rebuttal sufficient, 2 Insurer raised triable issue, 2 Insurer's proof insufficient, 4 Trial error, new trial)2010, Appellate Term: 66 decisions (50 Unrebutted, insurer prevails, 5 Provider's rebuttal sufficient, 9 Insurer raised triable issue, 2 Insurer's proof insufficient)2009, Appellate Term: 32 decisions (17 Unrebutted, insurer prevails, 2 Provider's rebuttal sufficient, 9 Insurer raised triable issue, 4 Insurer's proof insufficient)2008, Appellate Term: 29 decisions (14 Unrebutted, insurer prevails, 9 Insurer raised triable issue, 6 Insurer's proof insufficient)2007, Appellate Term: 9 decisions (3 Unrebutted, insurer prevails, 3 Insurer raised triable issue, 2 Insurer's proof insufficient, 1 Trial error, new trial)2006, Appellate Term: 20 decisions (1 Unrebutted, insurer prevails, 11 Insurer raised triable issue, 8 Insurer's proof insufficient)2005, Appellate Term: 16 decisions (6 Insurer raised triable issue, 10 Insurer's proof insufficient)2004, Appellate Term: 10 decisions (1 Insurer raised triable issue, 9 Insurer's proof insufficient)2003, Appellate Term: 1 decision (1 Insurer raised triable issue)2022, Trial courts: 6 decisions (4 Unrebutted, insurer prevails, 1 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2021, Trial courts: 2 decisions (1 Unrebutted, insurer prevails, 1 Provider's rebuttal sufficient)2017, Trial courts: 2 decisions (1 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2015, Trial courts: 1 decision (1 Unrebutted, insurer prevails)2014, Trial courts: 3 decisions (2 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2013, Trial courts: 2 decisions (1 Unrebutted, insurer prevails, 1 Trial error, new trial)2012, Trial courts: 7 decisions (4 Unrebutted, insurer prevails, 3 Insurer's proof insufficient)2011, Trial courts: 4 decisions (4 Insurer's proof insufficient)2010, Trial courts: 10 decisions (2 Unrebutted, insurer prevails, 7 Insurer's proof insufficient, 1 Trial error, new trial)2009, Trial courts: 5 decisions (2 Unrebutted, insurer prevails, 2 Insurer raised triable issue, 1 Insurer's proof insufficient)2008, Trial courts: 11 decisions (6 Unrebutted, insurer prevails, 5 Insurer's proof insufficient)2007, Trial courts: 5 decisions (1 Provider's rebuttal sufficient, 4 Insurer's proof insufficient)2006, Trial courts: 9 decisions (2 Unrebutted, insurer prevails, 1 Insurer raised triable issue, 6 Insurer's proof insufficient)2005, Trial courts: 9 decisions (2 Unrebutted, insurer prevails, 1 Insurer raised triable issue, 6 Insurer's proof insufficient)2004, Trial courts: 8 decisions (1 Unrebutted, insurer prevails, 1 Insurer raised triable issue, 5 Insurer's proof insufficient, 1 Trial error, new trial)2003, Trial courts: 1 decision (1 Insurer's proof insufficient)2026, Trial courts: 1 decision (1 Provider's rebuttal sufficient)2025, Trial courts: 1 decision (1 Unrebutted, insurer prevails)This decision
20052010201520202025
Unrebutted, insurer prevailsProvider's rebuttal sufficientInsurer raised triable issueInsurer's proof insufficientTrial error, new trialThis decisionCites it or cited by itCited or followed

Of the 617 decisions on this question in the Second Department courts and the Court of Appeals, 315 (this one included) are in the same category.

Cited in this decision

A label shows how this decision treated the case it cites.

  • Radiology Today, P.C. v Geico Ins. Co. (2017 NY Slip Op 51768(U)) FollowedAn insurer may present substitute expert testimony on medical necessity without admitting the peer review report for its truth.
  • Park Slope Med. & Surgical Supply, Inc. v Progressive Ins. Co. (2012 NY Slip Op 50349(U)) FollowedAn insurer's trial expert may testify on medical necessity without having authored the peer review, within the original report's denial basis.

Similar decisions

  • New Horizon Surgical Ctr., L.L.C. v Allstate Ins. Co. (2016 NY Slip Op 51125(U))The insurer's unrebutted chiropractic expert testimony established that the MUA procedure and related facility fee lacked medical necessity.
  • Mollo v 21st Century Ins. Co. (2019 NY Slip Op 51182(U))The insurer established timely mailing of EUO scheduling letters and denials despite separate delay letters that did not toll its deadline.
  • American Chiropractic Care, P.C. v Praetorian Ins. Co. (2014 NY Slip Op 50346(U))The provider's treating chiropractor's sworn letter raised a factual issue on medical necessity despite the insurer's peer review.
  • Synergy Med. v Praetorian Ins. Co. (2013 NY Slip Op 51047(U))The insurer's sworn peer review established lack of medical necessity, and the provider's unsworn, conclusory reports raised no triable issue.
  • Orlin & Cohen Orthopedic Assoc. v Allstate Ins. Co. (2017 NY Slip Op 50937(U))The provider failed to prove that spinal surgery was medically necessary after the insurer rebutted the presumption of necessity.
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