November 6, 2020
EA Chiropractic Diagnostics, P.C. v GEICO Ins. (2020 NY Slip Op 51331(U))
https://www.beynensonlaw.com/case-law/ea-chiropractic-diagnostics-p-c-v-geico-ins-2020-ny-slip-op51331u/
- Decided
- November 6, 2020
- Citation
- 2020 NY Slip Op 51331(U)
- Posture
- Summary judgment
- Outcome
- Split result
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.
Reported in New York Official Reports at EA Chiropractic Diagnostics, P.C. v GEICO Ins. (2020 NY Slip Op 51331(U))
SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT, 2d, 11th and 13th JUDICIAL DISTRICTS
against
GEICO Insurance, Appellant.
Rivkin Radler, LLP (Stuart M. Bodoff of counsel), for appellant. Zara Javakov, P.C. (Zara Javakov of counsel), for respondent.
Appeal from an order of the Civil Court of the City of New York, Kings County (Odessa Kennedy, J.), entered September 12, 2018. The order, insofar as appealed from, denied defendant’s cross motion for summary judgment dismissing the complaint.
ORDERED that the order, insofar as appealed from, is modified by providing that the branch of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon a claim for services rendered from May 19, 2016 through May 25, 2016 is granted; as so modified, the order, insofar as appealed from, is affirmed, without costs.
In this action by a provider to recover assigned first-party no-fault benefits, defendant appeals from so much of an order of the Civil Court as denied defendant’s cross motion which had sought summary judgment dismissing the complaint on the grounds that plaintiff had failed to appear for duly scheduled examinations under oath (EUOs) and that plaintiff’s assignor had failed to appear for duly scheduled independent medical examinations (IMEs).
In support of the branch of its cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon a claim for services rendered from May 19, 2016 through May 25, 2016, defendant submitted an affidavit by the general manager of Empire Stat Med Review, P.C., which had been retained by defendant to schedule IMEs, which affidavit sufficiently established that the IME scheduling letters had been timely mailed (see St. Vincent’s Hosp. of Richmond v Government Empls. Ins. Co., 50 AD3d 1123 [2008]). Defendant also established that the assignor failed to appear for the duly scheduled IMEs (see Stephen Fogel [*2]Psychological, P.C. v Progressive Cas. Ins. Co., 35 AD3d 720 [2006]). Thus, defendant demonstrated that plaintiff failed to comply with a condition precedent to coverage (id. at 722). As defendant’s cross motion further established that defendant timely denied (see St. Vincent’s Hosp. of Richmond, 50 AD3d 1123) the claim on that ground, and plaintiff failed to raise a triable issue of fact in opposition to this branch of defendant’s cross motion, the branch of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon a claim for services rendered from May 19, 2016 through May 25, 2016 should have been granted.
Contrary to defendant’s contention, defendant’s cross motion failed to establish that defendant had timely denied the remaining claims at issue after plaintiff allegedly failed to appear at both an initial and a follow-up EUO. As defendant did not demonstrate that it is not precluded from raising this proffered defense (see Westchester Med. Ctr. v Lincoln Gen. Ins. Co., 60 AD3d 1045 [2009]), defendant is not entitled to summary judgment upon the branch of its cross motion seeking summary judgment dismissing the remaining portion of the complaint.
Accordingly, the order, insofar as appealed from, is modified by providing that the branch of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon a claim for services rendered from May 19, 2016 through May 25, 2016 is granted.
ALIOTTA, P.J., ELLIOT and SIEGAL, JJ., concur.
ENTER:
Paul Kenny
Chief Clerk
Decision Date: November 6, 2020
Legal questions (3)
Questions 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.
Is an IME/EUO no-show defense precluded if the insurer did not timely deny the claim on that ground?
This decision: No-show defense is subject to preclusion and fails for want of a timely, proper denial
Granted dismissal of one claim timely denied after the IME no-show, but held the insurer did not show it timely denied the remaining claims after the EUO nonappearances, so it did not show it was not precluded.
Of the 500 decisions on this question in the Second Department courts and the Court of Appeals, 162 (this one included) are in the same category.
Did a party’s evidence establish that it mailed a no-fault claim, denial, verification request or examination notice?
This decision: The insurer's (or its agent's) proof established mailing of its denial, verification request or IME/EUO notice (rules on the question, but another ground decided the case)
Held the affidavit of the IME scheduling company's general manager sufficiently established that the IME scheduling letters were timely mailed, and the denial was shown timely.
Of the 1,384 decisions on this question in the Second Department courts and the Court of Appeals, 806 (this one included) are in the same category.
Did the insurer prove its IME/EUO no-show defense: mailed, compliant scheduling requests and the claimant’s nonappearance?
This decision: Insurer proved mailed, compliant requests and the nonappearance; claimant's answers rejected (rules on the question, but another ground decided the case)
Held the IME scheduler's affidavit established timely mailing of the IME letters and the insurer showed the assignor failed to appear, for one claim.
Of the 851 decisions on this question in the Second Department courts and the Court of Appeals, 525 (this one included) are in the same category.
Cited in this decision
A label shows how this decision treated the case it cites.
- St. Vincent’s Hosp. of Richmond v Government Empls. Ins. Co. (2008 NY Slip Op 04072) FollowedThe insurer raised factual issues concerning a proper timely denial and its entitlement to deny the hospital's claim.
- Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co. (2006 NY Slip Op 09604) FollowedAn insurer may deny benefits retroactively to the date of loss for failure to attend reasonably required IMEs under 11 NYCRR 65-1.1.
- Westchester Med. Ctr. v Lincoln Gen. Ins. Co. (2009 NY Slip Op 02589) FollowedThe insurer's investigation letters did not toll the 30-day period to pay or deny the provider's claim.
Similar decisions
- Parkview Med. & Surgical, P.C. v Geico Gen. Ins. Co. (2014 NY Slip Op 51822(U))The insurer proved the assignor's IME nonappearances but failed to establish its fee schedule defense for other claims.
- NL Quality Med., P.C. v GEICO Ins. Co. (2020 NY Slip Op 51340(U))The insurer proved EUO nonappearance and a policy deductible on four causes of action, but its fee-schedule proof failed on the second.
- Compas Med., P.C. v Geico Ins. Co. (2015 NY Slip Op 51590(U))The insurer's conclusory IME nonappearance proof and the provider's deficient prima facie showing defeated both motions on the third cause of action.
- Chi P&L Acupuncture, P.C. v GEICO Gen. Ins. Co. (2022 NY Slip Op 50768(U))The insurer failed to establish timely denials after the provider missed both the initial and follow-up EUOs. The Appellate Term, Second Department, affirmed the order, insofar as appealed from, denying the insurer summary judgment dismissing the assigned no-fault claims.
- Focus Chiropractic, P.C. v Global Liberty Ins. Co. of N.Y. (2020 NY Slip Op 51006(U))The insurer established timely mailing of IME notices and the assignor's nonappearance, warranting dismissal of the claim at issue.