December 23, 2011
Jamaica Med. Supply, Inc. v American Tr. Ins. Co. (2011 NY Slip Op 52371(U))
https://www.beynensonlaw.com/case-law/jamaica-med-supply-inc-v-american-tr-ins-co-2011-ny-slip-op52371u/
- Decided
- December 23, 2011
- Citation
- 2011 NY Slip Op 52371(U) · 34 Misc 3d 133(A)
- Posture
- Summary judgment
- Outcome
- Insurer prevailed
- Later treatment
- Followed in 6 later decisions (see Cited by)
- Issues
- Priority, other coverage
- Legal questions
- Workers' comp or other insurer primary (see the maps)
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 Jamaica Med. Supply, Inc. v American Tr. Ins. Co. (2011 NY Slip Op 52371(U))
| Jamaica Med. Supply, Inc. v American Tr. Ins. Co. |
| 2011 NY Slip Op 52371(U) [34 Misc 3d 133(A)] |
| Decided on December 23, 2011 |
| Appellate Term, Second Department |
| Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. |
| This opinion is uncorrected and will not be published in the printed Official Reports. |
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE TERM: 2nd, 11th and 13th JUDICIAL DISTRICTS
PRESENT: : PESCE, P.J., GOLIA and STEINHARDT, JJ
2010-1681 K C.
against
American Transit Ins. Co., Appellant.
Appeal from an order of the Civil Court of the City of New York, Kings County (Alice Fisher Rubin, J.), entered August 7, 2009. The order, insofar as appealed from, denied defendant’s cross motion for summary judgment.
ORDERED that the order, insofar as appealed from, is reversed, without costs, and defendant’s cross motion for summary judgment is remitted to the Civil Court for a new determination after final resolution of a prompt application to the Workers’ Compensation Board to determine the parties’ rights under the Workers’ Compensation Law. In the event plaintiff fails to file proof with the Civil Court of such application within 90 days of the date of this decision and order, the Civil Court shall grant defendant’s cross motion for summary judgment dismissing the complaint unless plaintiff shows good cause why the complaint should not be dismissed.
In this action by a provider to recover assigned first-party no-fault benefits, plaintiff moved for summary judgment, and defendant cross-moved for summary judgment dismissing the complaint based upon plaintiff’s assignor’s alleged eligibility for workers’ compensation benefits. The Civil Court denied both the motion and the cross motion, finding that defendant had “failed [*2]to preserve a defense of Workers’ Compensation being . . . primary.” Defendant appeals from so much of the order as denied its cross motion.
Defendant proffered sufficient evidence in admissible form of the alleged facts which gave rise to its contention that there was a triable issue as to whether plaintiff’s assignor had been acting as an employee at the time of the accident, and that therefore workers’ compensation benefits might be available (see e.g. 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, 11th & 13th Jud Dists 2010]; AR Med. Rehabilitation, P.C. v American Tr. Ins. Co., 27 Misc 3d 133[A], 2010 NY Slip Op 50708[U] [App Term, 2d, 11th & 13th Jud Dists 2010]; Response Equip., Inc. v American Tr. Ins. Co., 15 Misc 3d 145[A], 2007 NY Slip Op 51176[U] [App Term, 2d & 11th Jud Dists 2007]; cf. Westchester Med. Ctr. v American Tr. Ins. Co., 60 AD3d 848 [2009]). This issue must be resolved in the first instance by the Workers’ Compensation Board (Board) (see O’Rourke v Long, 41 NY2d 219, 225 [1976]; see also Dunn v American Tr. Ins. Co., 71 AD3d 629 [2010]; D.A.V. Chiropractic, P.C. v American Tr. Ins. Co., 29 Misc 3d 128[A], 2010 NY Slip Op 51738[U]; AR Med. Rehabilitation, P.C. v American Tr. Ins. Co., 27 Misc 3d 133[A], 2010 NY Slip Op 50708[U]; Response Equip., Inc. v American Tr. Ins. Co., 15 Misc 3d 145[A], 2007 NY Slip Op 51176[U]).
Accordingly, defendant’s cross motion should not have been denied. Instead, the Civil Court should determine the cross motion after final Board resolution. A prompt application to the Board, as set forth above, is required in order to determine the parties’ rights under the Workers’ Compensation Law (see Dunn v American Tr. Ins. Co., 71 AD3d 629; LMK Psychological Serv., P.C. v American Tr. Ins. Co., 64 AD3d 752 [2009]).
Pesce, P.J., Golia and Steinhardt, JJ., concur.
Decision Date: December 23, 2011
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.
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 admissible proof raised a triable issue whether the assignor was an employee, an issue for the Workers' Compensation Board first, and remitted the cross motion pending a prompt Board application with a 90-day dismissal clause.
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.
- 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.
- AR Med. Rehabilitation, P.C. v American Tr. Ins. Co. (2010 NY Slip Op 50708(U))The insurer's evidence required the Workers' Compensation Board to resolve the assignor's alleged eligibility for workers' compensation benefits.
- Response Equip., Inc. v American Tr. Ins. Co. (2007 NY Slip Op 51176(U))The Workers' Compensation Board must resolve whether the assignor was acting as an employee when the accident occurred.
- 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) FollowedThe Workers' Compensation Board has primary jurisdiction to resolve disputed employment status bearing on entitlement to workers' compensation benefits.
- LMK Psychological Serv., P.C. v American Tr. Ins. Co. (2009 NY Slip Op 06004) FollowedThe Workers' Compensation Board has primary jurisdiction to determine factual issues concerning workers' compensation coverage.
Cited by (12)
A label shows how the later decision treated this one.
- Arce Med. & Diagnostic Svce v American Tr. Ins. Co. (2013 NY Slip Op 50531(U)) FollowedThe insurer obtained a stay because admissible evidence raised an issue whether the assignor was eligible for workers' compensation benefits.
- Compas Med., P.C. v American Tr. Ins. Co. (2015 NY Slip Op 51675(U)) FollowedThe assignor's sworn no-fault application raised a workers' compensation issue requiring a stay pending a Workers' Compensation Board determination.
- Great Health Care Chiropractic, P.C. v Lancer Ins. Co. (2014 NY Slip Op 50340(U)) FollowedThe insurer raised a triable issue of workers' compensation eligibility requiring initial resolution by the Workers' Compensation Board.
- New Millennium Radiology, P.C. v American Tr. Ins. Co. (2018 NY Slip Op 50940(U)) FollowedThe insurer's evidence raised an employment-related coverage issue requiring an initial Workers' Compensation Board determination.
- W.H.O. Acupuncture, P.C. v American Tr. Ins. Co. (2013 NY Slip Op 50532(U)) FollowedThe insurer's evidence raised a workers' compensation eligibility issue requiring initial resolution by the Workers' Compensation Board.
- Ultimate Massage Therapy, P.C. v Utica Mut. Ins. Co. (2020 NY Slip Op 51613(U)) FollowedThe Workers' Compensation Board has primary jurisdiction to determine whether the Workers' Compensation Law applies.
- Quality Health Prod., Inc. v American Tr. Ins. Co. (2019 NY Slip Op 51950(U))The insurer established an employment-related coverage issue requiring an initial determination by the Workers' Compensation Board.
- Madison Prods. of USA, Inc. v American Tr. Ins. Co. (2020 NY Slip Op 50749(U))A workers' compensation defense is precluded by an untimely denial, requiring a threshold timeliness determination before a stay.
- 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.
- Compas Med., P.C. v American Tr. Ins. Co. (2017 NY Slip Op 51192(U))The insurer's evidence raised an issue of workers' compensation eligibility requiring initial resolution by the Workers' Compensation Board.
Similar decisions
- Active Care Med. Supply Corp. v American Tr. Ins. Co. (2019 NY Slip Op 50419(U))The Workers' Compensation Board must first resolve eligibility when evidence raises an issue whether the assignor was injured in the course of employment.
- A.B. Med. Servs., PLLC v American Tr. Ins. Co. (2009 NY Slip Op 29271)The insurer's proof raised a factual question about the assignor's employment status that required Workers' Compensation Board resolution.