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June 26, 2020

Madison Prods. of USA, Inc. v American Tr. Ins. Co. (2020 NY Slip Op 50749(U))

https://www.beynensonlaw.com/case-law/madison-prods-of-usa-inc-v-american-tr-ins-co-2020-ny-slip-op50749u/

Court
Appellate Term, Second Department
Decided
June 26, 2020
Citation
2020 NY Slip Op 50749(U)
Posture
Other motion
Outcome
Split result
Issues
Priority, other coverage Timeliness and preclusion Discovery and procedure
Legal questions
Workers' comp or other insurer primary (see the maps)
Cite as
Madison Prods. of USA, Inc. v American Tr. Ins. Co., 2020 NY Slip Op 50749(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.

A workers' compensation defense is precluded by an untimely denial, requiring a threshold timeliness determination before a stay. The insurer raised an employment-related coverage issue for the Workers' Compensation Board, which has primary jurisdiction under the Workers' Compensation Law. The Appellate Term, Second Department, upheld holding the first four causes of action in abeyance but required a framed issue hearing to determine receipt and denial timeliness for the fifth claim. A timely denial would permit holding that claim in abeyance; an untimely denial would preclude the defense and permit consideration of the provider's summary judgment request. The order was modified to hold the provider's motion in abeyance rather than deny it and to remit the fifth-claim stay request for redetermination.

Reported in New York Official Reports at Madison Prods. of USA, Inc. v American Tr. Ins. Co. (2020 NY Slip Op 50749(U))

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

Madison Products of USA, Inc., as Assignee of Pierre, Luxio, Appellant,

against

American Transit Ins. Co., Respondent.

The Rybak Firm, PLLC (Damin J. Toell of counsel), for appellant. Law Offices of Daniel J. Tucker (Matteo G. Sandusky of counsel), for respondent.

Appeal from an order of the Civil Court of the City of New York, Kings County (Joy F. Campanelli, J.), entered February 15, 2017. The order denied plaintiff’s motion for summary judgment and granted defendant’s cross motion to, in effect, hold the proceeding in abeyance pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law.

ORDERED that the order is modified by deleting the provision thereof granting the branch of defendant’s cross motion seeking, in effect, to hold the fifth cause of action in abeyance pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law and the provision thereof denying plaintiff’s motion for summary judgment, and substituting, for the latter, a provision holding plaintiff’s motion in abeyance until it is ripe for determination; as so modified, the order is affirmed, without costs, and the matter is remitted to the Civil Court for a new determination, following a framed issue hearing, of the branch of defendant’s cross motion seeking, in effect, to hold the fifth cause of action in abeyance pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law, in accordance with this decision.

In this action by a provider to recover assigned first-party no-fault benefits, plaintiff asserted five causes of action based on five claims and moved for summary judgment thereon. Defendant cross-moved for an order staying the action pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law and directing that, in the event plaintiff fails to file proof with the court of such an application to the Workers’ Compensation Board within 90 days of the date of the court’s order, defendant would be granted summary judgment dismissing the complaint. Defendant argued that plaintiff’s assignor had been [*2]injured during the course of his employment. By order entered February 15, 2017, the Civil Court denied plaintiff’s motion and granted defendant’s cross motion.

Contrary to plaintiff’s contention, defendant proffered sufficient evidence to support its contention that there was an issue as to whether plaintiff’s assignor had been acting in the course of his employment at the time of the accident and that, therefore, workers’ compensation benefits might be available (see e.g. Arce Med. & Diagnostic Svce v American Tr. Ins. Co., 39 Misc 3d 134[A], 2013 NY Slip Op 50531[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2013]; Jamaica Med. Supply, Inc. v American Tr. Ins. Co., 34 Misc 3d 133[A], 2011 NY Slip Op 52371[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2011]; D.A.V. Chiropractic, P.C. v American Tr. Ins. Co., 29 Misc 3d 128[A], 2010 NY Slip Op 51738[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2010]; cf. Westchester Med. Ctr. v American Tr. Ins. Co., 60 AD3d 848 [2009]). “Since ‘primary jurisdiction with respect to determinations as to the applicability of the Workers’ Compensation Law has been vested in the Workers’ Compensation Board,’ it is ‘inappropriate for the courts to express views with respect thereto pending determination by the board’ ” (Monteiro v Rasraj Foods & Catering, Inc., 79 AD3d 827, 829 [2010], quoting Botwinick v Ogden, 59 NY2d 909, 911 [1983]). This issue must be resolved in the first instance by the Workers’ Compensation Board (see O’Rourke v Long, 41 NY2d 219 [1976]; Siekkeli v Mark Mariani, Inc., 119 AD3d 766 [2014]; Dunn v American Tr. Ins. Co., 71 AD3d 629, 629-630 [2010]; Jamaica Med. Supply, Inc. v American Tr. Ins. Co., 34 Misc 3d 133[A], 2011 NY Slip Op 52371[U]; D.A.V. Chiropractic, P.C. v American Tr. Ins. Co., 29 Misc 3d 128[A], 2010 NY Slip Op 51738[U]).

In light of the foregoing, the Civil Court properly granted the branches of defendant’s cross motion seeking, in effect, to hold the first through fourth causes of action in abeyance pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law; however, instead of denying plaintiff’s motion for summary judgment, the court should have held that motion in abeyance until, if ever, it becomes ripe for determination. Moreover, with respect to the fifth cause of action, plaintiff correctly argues that there is a threshold issue to be decided—namely, whether defendant’s workers’ compensation defense is precluded as to that cause of action because defendant failed to timely deny the claim (see Westchester Med. Ctr. v Lincoln Gen. Ins. Co., 60 AD3d 1045, 1046 [2009]; Friedman v Allstate Ins. Co., 51 Misc 3d 129[A], 2016 NY Slip Op 50390[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2016]). On the record before us, the date on which defendant received the claim underlying the fifth cause of action cannot be determined; consequently, this issue of fact must first be resolved following a framed issue hearing. If, after that hearing, the Civil Court finds that defendant timely denied the claim, the branch of defendant’s cross motion seeking to hold this cause of action in abeyance pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law should be granted, for the reasons stated above. If the Civil Court finds that defendant did not timely deny the claim, the branch of defendant’s cross motion seeking to hold that cause of action in abeyance should be denied, as defendant’s defense based on the Workers’ Compensation Law would be precluded; whereupon, the branch of plaintiff’s motion seeking summary judgment on that cause of action will become ripe for resolution by the Civil Court.

Accordingly, the order is modified by deleting the provision thereof granting the branch [*3]of defendant’s cross motion seeking, in effect, to hold the fifth cause of action in abeyance pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law and the provision thereof denying plaintiff’s motion for summary judgment, and substituting, for the latter, a provision holding plaintiff’s motion in abeyance until it is ripe for determination, and the matter is remitted to the Civil Court for a new determination, following a framed issue hearing, of the branch of defendant’s cross motion seeking, in effect, to hold the fifth cause of action in abeyance pending a determination by the Workers’ Compensation Board of the parties’ rights under the Workers’ Compensation Law.

WESTON and ALIOTTA, JJ., concur.

PESCE, P.J., taking no part.


ENTER:
Paul Kenny
Chief Clerk
Decision Date: June 26, 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.

Workers' comp or other insurer primary

Open the full map

Can a no-fault insurer deny or delay payment because workers’ compensation or another insurer is primary?

This decision: Workers' compensation may apply: the Board decides first and the no-fault claim waits

Held the insurer's proof raised an issue whether the assignor was injured in the course of employment, so four claims were properly held in abeyance for the Board, while a hearing must decide whether the fifth claim's WC defense was precluded by untimely denial.

  • Appellate DivisionApp Div 8
  • Appellate TermApp Term 42
  • Trial courtsTrial 19
2014, Appellate Division: 1 decision (1 First insurer must pay)2010, Appellate Division: 1 decision (1 Referred to WC Board)2009, Appellate Division: 3 decisions (1 Referred to WC Board, 1 WC defense not shown, 1 WC defense precluded)2007, Appellate Division: 2 decisions (1 Referred to WC Board, 1 WC defense not shown)2024, Appellate Division: 1 decision (1 Referred to WC Board)2021, Appellate Term: 1 decision (1 Referred to WC Board)2020, Appellate Term: 1 decision (1 Referred to WC Board)2019, Appellate Term: 6 decisions (4 Referred to WC Board, 1 WC primary: claim fails, 1 WC defense precluded)2018, Appellate Term: 4 decisions (1 Referred to WC Board, 3 WC primary: claim fails)2017, Appellate Term: 4 decisions (3 Referred to WC Board, 1 WC primary: claim fails)2016, Appellate Term: 1 decision (1 WC defense precluded)2015, Appellate Term: 1 decision (1 Referred to WC Board)2014, Appellate Term: 2 decisions (1 Referred to WC Board, 1 WC primary: claim fails)2013, Appellate Term: 4 decisions (3 Referred to WC Board, 1 WC defense not shown)2012, Appellate Term: 4 decisions (1 Referred to WC Board, 3 WC primary: claim fails)2011, Appellate Term: 1 decision (1 Referred to WC Board)2010, Appellate Term: 3 decisions (3 Referred to WC Board)2009, Appellate Term: 6 decisions (3 Referred to WC Board, 1 WC defense not shown, 2 WC defense precluded)2007, Appellate Term: 1 decision (1 Referred to WC Board)2005, Appellate Term: 2 decisions (1 WC defense not shown, 1 First insurer must pay)2008, Appellate Term: 1 decision (1 Referred to WC Board)2023, Trial courts: 3 decisions (1 WC primary: claim fails, 2 WC defense not shown)2022, Trial courts: 1 decision (1 No coverage, not priority)2021, Trial courts: 2 decisions (1 Referred to WC Board, 1 WC defense not shown)2019, Trial courts: 1 decision (1 No coverage, not priority)2018, Trial courts: 1 decision (1 Referred to WC Board)2016, Trial courts: 1 decision (1 Referred to WC Board)2009, Trial courts: 3 decisions (1 WC defense not shown, 2 WC defense precluded)2008, Trial courts: 2 decisions (1 WC defense not shown, 1 WC defense precluded)2007, Trial courts: 1 decision (1 First insurer must pay)2005, Trial courts: 1 decision (1 Referred to WC Board)2026, Trial courts: 3 decisions (2 WC defense precluded, 1 First insurer must pay)This decision
20052010201520202025
Referred to WC BoardWC primary: claim failsWC defense not shownWC defense precludedFirst insurer must payNo coverage, not priorityThis decisionCites it or cited by itCited or followedDistinguished or limited

Of the 69 decisions on this question in the Second Department courts and the Court of Appeals, 33 (this one included) are in the same category.

Cited in this decision

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

  • Arce Med. & Diagnostic Svce v American Tr. Ins. Co. (2013 NY Slip Op 50531(U))The insurer obtained a stay because admissible evidence raised an issue whether the assignor was eligible for workers' compensation benefits.
  • Jamaica Med. Supply, Inc. v American Tr. Ins. Co. (2011 NY Slip Op 52371(U))The insurer raised a triable workers' compensation eligibility issue requiring initial resolution by the Workers' Compensation Board.
  • D.A.V. Chiropractic, P.C. v American Tr. Ins. Co. (2010 NY Slip Op 51738(U))The Workers' Compensation Board has primary jurisdiction to resolve factual questions about workers' compensation coverage.
  • Westchester Med. Ctr. v American Tr. Ins. Co. (2009 NY Slip Op 01979) Contrasted (cf., but see)The insurer's timely verification request and ensuing timely denial defeated the provider's motion for summary judgment.
  • Dunn v American Tr. Ins. Co. (2010 NY Slip Op 01757)The Workers' Compensation Board has primary jurisdiction to resolve disputed employment status bearing on entitlement to workers' compensation benefits.
  • Westchester Med. Ctr. v Lincoln Gen. Ins. Co. (2009 NY Slip Op 02589)The insurer's investigation letters did not toll the 30-day period to pay or deny the provider's claim.
  • Friedman v Allstate Ins. Co. (2016 NY Slip Op 50390(U))The provider proved by a preponderance of the credible evidence that the disputed acupuncture treatments were medically necessary.

Cited by

  • American Tr. Ins. Co. v North Shore Family Chiropractic PC (2023 NY Slip Op 50208(U))The insurer's police report did not require referral of its course-of-employment defense to the Workers' Compensation Board.

Similar decisions

  • New Millennium Radiology, P.C. v American Tr. Ins. Co. (2018 NY Slip Op 50940(U))The insurer's evidence raised an employment-related coverage issue requiring an initial Workers' Compensation Board determination.
  • A.B. Med. Servs., PLLC v American Tr. Ins. Co. (2009 NY Slip Op 51263(U))The insurer's workers' compensation defense was precluded for three claims denied after the 30-day determination period.
  • TAM Med. Supply Corp. v Country Wide Ins. Co. (2017 NY Slip Op 50921(U))The insurer's conflicting claim-receipt dates prevented summary judgment on late accident notice, but the provider was compelled to give discovery.
  • Compas Med., P.C. v American Tr. Ins. Co. (2015 NY Slip Op 51675(U))The assignor's sworn no-fault application raised a workers' compensation issue requiring a stay pending a Workers' Compensation Board determination.
  • JFL Med. Care, P.C. v Wesco Ins. Co. (2022 NY Slip Op 51376(U))The insurer failed to prove denial of one claim or materiality of the alleged misrepresentation supporting denial of the other.
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