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September 27, 2016

Stracar Med. Servs., P.C. v Allstate Prop. & Cas. Ins. Co. (2016 NY Slip Op 51431(U))

https://www.beynensonlaw.com/case-law/stracar-med-servs-p-c-v-allstate-prop-cas-ins-co-2016-ny-slip-op51431u/

Court
Appellate Term, Second Department
Decided
September 27, 2016
Citation
2016 NY Slip Op 51431(U)
Posture
Summary judgment
Outcome
Insurer prevailed
Issues
IME no-show
Legal questions
No-show defense: insurer's proof (see the maps)
Cite as
Stracar Med. Servs., P.C. v Allstate Prop. & Cas. Ins. Co., 2016 NY Slip Op 51431(U) (App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2016)

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 assignor's attendance at other IMEs raised no factual issue concerning the reasonableness of the orthopedic IME requests at issue. Under 11 NYCRR 65-1.1, an eligible injured person must attend IMEs as often as the insurer reasonably requires. The other examinations were generally in different specialties, and the prior orthopedic report recommended reevaluation after four weeks, approximately when the first disputed IME was scheduled. The provider also failed to allege or prove any response to the requests, so its objections should not have been considered. The Appellate Term, Second Department, reversed the order, insofar as appealed from, and granted the insurer summary judgment dismissing the claims denied for IME nonappearance; the insurer's entitlement was otherwise unchallenged.

Reported in New York Official Reports at Stracar Med. Servs., P.C. v Allstate Prop. & Cas. Ins. Co. (2016 NY Slip Op 51431(U))

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

Stracar Medical Services, P.C., as Assignee of ETHEL BRANCHCOMB, Respondent,

against

Allstate Property and Casualty Insurance Company, Appellant.

Appeal from an order of the Civil Court of the City of New York, Kings County (Robin S. Garson, J.), entered March 13, 2014. The order, insofar as appealed from and as limited by the brief, denied the branches of defendant’s motion seeking summary judgment dismissing so much of the complaint as sought to recover upon claims which had been denied based on plaintiff’s assignor’s failure to appear for independent medical examinations.

ORDERED that the order, insofar as appealed from, is reversed, with $30 costs, and the branches of defendant’s motion seeking summary judgment dismissing so much of the complaint as sought to recover upon claims which had been denied based on plaintiff’s assignor’s failure to appear for independent medical examinations are granted.

In this action by a provider to recover assigned first-party no-fault benefits, defendant moved for summary judgment, seeking, among other things, to dismiss so much of the complaint as sought to recover upon claims which had been denied on the ground that plaintiff’s assignor had failed to appear for independent medical examinations (IMEs). Insofar as is relevant to this appeal, the Civil Court denied those branches of defendant’s motion and held that the only remaining issue for trial as to those claims was the reasonableness of the IME requests. Defendant argues on appeal that these branches of its motion should have been granted.

The court found that there was a question as to the reasonableness of the IME requests because there was evidence that plaintiff’s assignor had appeared for other IMEs. However, the no-fault regulations provide that an eligible injured person “shall submit” to IMEs “when, and as often as, the Company may reasonably require” (11 NYCRR 65-1.1; see also Power Supply, Inc. v Praetorian Ins. Co., 46 Misc 3d 146[A], 2015 NY Slip Op 50218[U], *1 [App Term, 2d Dept, 9th & 10th Jud Dists 2015] [“an assignor’s appearance for any duly scheduled IME or EUO is a condition precedent to the insurer’s liability on the policy”]). Contrary to the finding of the Civil Court, the record does not raise any question as to the reasonableness of the IME requests at issue, which were for an orthopedic examination. While, in its cross motion and opposition to defendant’s motion, plaintiff attached reports from other IMEs of the assignor, most of those IMEs were in different specialties, such as acupuncture. The only other orthopedic IME report attached, which is dated about four weeks before the first scheduled IME at issue in this case, specifically states that treatment should continue for four weeks, at which time the claimant “should be re-evaluated.”

In any event, plaintiff’s objections regarding the IME requests should not have been [*2]considered by the Civil Court, as plaintiff did not allege, much less prove, that its assignor had responded in any way to the IME requests (see e.g. Westchester County Med. Ctr. v New York Cent. Mut. Fire Ins. Co., 262 AD2d 553 [1999]; Eagle Surgical Supply, Inc. v AIG Ins. Co., 36 Misc 3d 153[A], 2012 NY Slip Op 51711[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2012]).

As plaintiff has not challenged the Civil Court’s finding, in effect, that defendant is otherwise entitled to judgment on the claims at issue, the order, insofar as appealed from, is reversed and the branches of defendant’s motion seeking summary judgment dismissing so much of the complaint as sought to recover upon claims which had been denied based on plaintiff’s assignor’s failure to appear for IMEs are granted.

Pesce, P.J., Aliotta and Solomon, JJ., concur.


Decision Date: September 27, 2016

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.

No-show defense: insurer's proof

Open the full map

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

Held the record raised no question about the reasonableness of the orthopedic IME requests, and the provider could not object to them anyway because the assignor never responded to the requests.

  • Appellate DivisionApp Div 9
  • Appellate TermApp Term 753
  • Trial courtsTrial 89
2023, Appellate Division: 1 decision (1 Defense proved)2020, Appellate Division: 1 decision (1 Defense proved)2016, Appellate Division: 2 decisions (2 Mailing not proved)2015, Appellate Division: 1 decision (1 Mailing not proved)2014, Appellate Division: 2 decisions (2 Defense proved)2006, Appellate Division: 1 decision (1 Mailing not proved)2004, Appellate Division: 1 decision (1 No-show excused)2023, Appellate Term: 5 decisions (5 Defense proved)2022, Appellate Term: 45 decisions (37 Defense proved, 3 Mailing not proved, 3 Nonappearance not proved, 2 Requests not compliant)2021, Appellate Term: 22 decisions (16 Defense proved, 3 Mailing not proved, 1 Requests not compliant, 2 Triable issue)2020, Appellate Term: 30 decisions (26 Defense proved, 2 Mailing not proved, 2 Requests not compliant)2019, Appellate Term: 68 decisions (52 Defense proved, 1 Mailing not proved, 1 Nonappearance not proved, 13 Requests not compliant, 1 Triable issue)2018, Appellate Term: 52 decisions (43 Defense proved, 3 Mailing not proved, 1 Nonappearance not proved, 5 Requests not compliant)2017, Appellate Term: 86 decisions (52 Defense proved, 14 Mailing not proved, 6 Nonappearance not proved, 11 Requests not compliant, 1 Triable issue, 2 No-show excused)2016, Appellate Term: 74 decisions (34 Defense proved, 14 Mailing not proved, 22 Nonappearance not proved, 3 Requests not compliant, 1 Triable issue)2015, Appellate Term: 77 decisions (48 Defense proved, 6 Mailing not proved, 14 Nonappearance not proved, 5 Requests not compliant, 4 Triable issue)2014, Appellate Term: 46 decisions (35 Defense proved, 5 Mailing not proved, 4 Nonappearance not proved, 2 Requests not compliant)2013, Appellate Term: 44 decisions (29 Defense proved, 6 Mailing not proved, 7 Nonappearance not proved, 1 Requests not compliant, 1 No-show excused)2012, Appellate Term: 51 decisions (37 Defense proved, 5 Mailing not proved, 1 Nonappearance not proved, 5 Requests not compliant, 2 Triable issue, 1 No-show excused)2011, Appellate Term: 33 decisions (27 Defense proved, 3 Mailing not proved, 2 Nonappearance not proved, 1 Triable issue)2010, Appellate Term: 14 decisions (9 Defense proved, 1 Mailing not proved, 2 Nonappearance not proved, 2 Requests not compliant)2009, Appellate Term: 15 decisions (6 Defense proved, 6 Mailing not proved, 2 Nonappearance not proved, 1 Requests not compliant)2008, Appellate Term: 7 decisions (2 Defense proved, 1 Mailing not proved, 4 Nonappearance not proved)2007, Appellate Term: 15 decisions (1 Defense proved, 6 Mailing not proved, 5 Nonappearance not proved, 3 Triable issue)2006, Appellate Term: 19 decisions (1 Defense proved, 8 Mailing not proved, 6 Requests not compliant, 4 Triable issue)2005, Appellate Term: 19 decisions (3 Defense proved, 10 Mailing not proved, 5 Requests not compliant, 1 No-show excused)2004, Appellate Term: 15 decisions (3 Defense proved, 1 Mailing not proved, 10 Requests not compliant, 1 Triable issue)2024, Appellate Term: 6 decisions (6 Defense proved)2025, Appellate Term: 7 decisions (7 Defense proved)2026, Appellate Term: 2 decisions (2 Defense proved)2003, Appellate Term: 1 decision (1 Requests not compliant)2023, Trial courts: 5 decisions (2 Defense proved, 1 Requests not compliant, 2 Triable issue)2022, Trial courts: 3 decisions (1 Defense proved, 1 Mailing not proved, 1 Requests not compliant)2021, Trial courts: 10 decisions (8 Defense proved, 2 Requests not compliant)2020, Trial courts: 3 decisions (2 Mailing not proved, 1 Requests not compliant)2019, Trial courts: 5 decisions (3 Mailing not proved, 2 Requests not compliant)2018, Trial courts: 3 decisions (1 Defense proved, 1 Nonappearance not proved, 1 Requests not compliant)2017, Trial courts: 6 decisions (2 Defense proved, 1 Nonappearance not proved, 2 Requests not compliant, 1 Triable issue)2016, Trial courts: 4 decisions (3 Defense proved, 1 Requests not compliant)2015, Trial courts: 1 decision (1 Defense proved)2014, Trial courts: 5 decisions (2 Defense proved, 1 Requests not compliant, 1 Triable issue, 1 No-show excused)2013, Trial courts: 7 decisions (3 Defense proved, 1 Nonappearance not proved, 2 Requests not compliant, 1 No-show excused)2012, Trial courts: 5 decisions (2 Defense proved, 3 Requests not compliant)2010, Trial courts: 3 decisions (2 Defense proved, 1 Requests not compliant)2009, Trial courts: 2 decisions (2 Defense proved)2008, Trial courts: 4 decisions (2 Defense proved, 2 Requests not compliant)2007, Trial courts: 1 decision (1 Mailing not proved)2006, Trial courts: 2 decisions (2 Mailing not proved)2005, Trial courts: 2 decisions (1 Defense proved, 1 Requests not compliant)2004, Trial courts: 7 decisions (1 Defense proved, 2 Mailing not proved, 4 Requests not compliant)2024, Trial courts: 2 decisions (1 Mailing not proved, 1 Requests not compliant)2025, Trial courts: 4 decisions (3 Defense proved, 1 Nonappearance not proved)2026, Trial courts: 4 decisions (3 Defense proved, 1 Nonappearance not proved)2011, Trial courts: 1 decision (1 Defense proved)This decision
20052010201520202025
Defense provedMailing not provedNonappearance not provedRequests not compliantTriable issueNo-show excusedThis decisionCites it or cited by itCited or followed

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.

  • Power Supply, Inc. v Praetorian Ins. Co. (2015 NY Slip Op 50218(U)) FollowedThe insurer's timely EUO requests tolled the denial period beyond the assignor's earlier IME nonappearances.

Similar decisions

  • Stracar Med. Servs. v New York Cent. Mut. Ins. Co. (2014 NY Slip Op 50263(U))An assignor's failure to attend requested IMEs permits retroactive denial of all claims to the loss date regardless of denial timeliness.
  • Arco Med. NY, P.C. v AIG Indem. Ins. Co. (2014 NY Slip Op 51257(U))The insurer established timely mailing of the IME notices and denials and the assignor's failure to appear for the scheduled IMEs. The providers sought assigned no-fault benefits, and the insurer moved for summary judgment on the claims denied for IME nonappearance.
  • 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.
  • Tri-Mount Acupuncture, P.C. v N.Y. Cent. Mut. Fire Ins. Co. (2011 NY Slip Op 50335(U))The insurer proved mailing of IME notices and timely denials and the assignor's nonappearance; the provider raised no triable issue.
  • Health Evolve Acupuncture, P.C. v Allstate Ins. Co. (2019 NY Slip Op 50691(U))The insurer's affirmations and affidavits from the scheduled examining providers established the assignor's failure to attend the IMEs. In the provider's assigned no-fault action, the Civil Court, Kings County, denied the insurer's cross motion but found, in effect under CPLR 3212 (g) that nonappearance was the only issue remaining for trial.
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