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June 9, 2005

A.B. Med. Servs. PLLC v American Tr. Ins. Co. (2005 NYSlipOp 50959(U))

https://www.beynensonlaw.com/case-law/a-b-med-servs-pllc-v-american-tr-ins-co-2005-nyslipop-50959u/

Court
Appellate Term, Second Department
Decided
June 9, 2005
Citation
2005 NY Slip Op 50959(U)
Posture
Summary judgment
Outcome
Provider prevailed
Later treatment
Contrasted (cf., but see) in 2 and followed in 4 later decisions (see Cited by)
Issues
Priority, other coverage Provider's prima facie case
Legal questions
Workers' comp or other insurer primary · Claimant's prima facie case on motions (see the maps)
Cite as
A.B. Med. Servs. PLLC v American Tr. Ins. Co., 2005 NY Slip Op 50959(U) (App Term, 2d Dept, 2d & 11th Jud Dists 2005)

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 failed to show potential merit in its workers' compensation defense sufficient to warrant Workers' Compensation Board review. The providers submitted sworn statements from the assignor and purported employer that the assignor was not working when the accident occurred. The insurer relied on an adjuster's determination based solely on an unsworn employer statement predating the accident by 18 months; a police report first offered in reply was not considered. Following Lanpont v Savvas Cab Corp., the defense was speculative and raised no factual issue requiring Board resolution. The Appellate Term, Second Department, modified the order to grant the providers summary judgment, left denial of the insurer's cross motion intact, and remanded for interest and attorney fees under Insurance Law § 5106 (a).

Reported in New York Official Reports at A.B. Med. Servs. PLLC v American Tr. Ins. Co. (2005 NYSlipOp 50959(U))

[*1]
A.B. Med. Servs. PLLC v American Tr. Ins. Co.
2005 NYSlipOp 50959(U)
Decided on June 9, 2005
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This opinion is uncorrected and will not be published in the printed Official Reports.
Decided on June 9, 2005

SUPREME COURT OF THE STATE OF NEW YORK

APPELLATE TERM: 2nd and 11th JUDICIAL DISTRICTS


PRESENT: June 9, 2005 SUPREME COURT OF THE STATE OF NEW YORK APPELLATE TERM : 2nd and 11th JUDICIAL DISTRICTS PRESENT : PESCE, P.J., PATTERSON and BELEN, JJ.
2004-1106 K C
A.B. Medical Services PLLC, D.A.V. Chiropractic P.C., Daniel Kim’s Acupuncture P.C., Somun Acupuncture P.C., a/a/o Aliguseyn Medzhidov, Appellants-Respondents,

against

American Transit Insurance Company, Respondent-Appellant.

Appeal by plaintiffs from so much of an order of the Civil Court, Kings County (E. Spodek, J.), entered June 21, 2004, as denied their motion for summary judgment. Cross appeal by defendant from so much of the same order as denied its cross motion for summary judgment.

Order unanimously modified by providing that plaintiffs’ motion for summary judgment is granted and matter remanded to the court below for a calculation of the statutory interest and an assessment of attorney’s fees; as so modified, affirmed without costs.

In this action to recover assigned first-party no-fault benefits for medical services provided their assignor, plaintiffs established their prima facie entitlement to summary judgment by evidentiary proof that they submitted statutory claim forms, setting forth the fact and the amount of the loss sustained, and that payment of no-fault benefits was overdue (see Insurance Law § 5106 [a]; Mary Immaculate Hosp. v Allstate Ins. Co., 5 AD3d 742 [2004]). Defendant insurer timely rejected the claims on the sole ground that at the time of the accident, assignor was acting in the course of his employment, mandating that plaintiffs pursue their compensation claim before the Workers’ Compensation Board (Board). Plaintiffs, alleging that the accident was not employment-related, moved for summary judgment, whereupon defendant cross-moved for summary judgment.

In our view, the insurer failed to establish the defense’s “potential merit” so as to warrant Board review of the facts (Lanpont v Savvas Cab Corp., 244 AD2d 208, 210 [1997]; see Alvarez [*2]v Prospect Hosp., 68 NY2d 320, 324 [1986]). As against plaintiffs’ proof, inter alia, assignor’s sworn statement that he was not working when the accident occurred and a sworn statement by his purported employer that assignor “was not
working on December 12, 2001″ (and necessarily, that assignor was not en route to or from work at the time of the incident [Baughman v Merchants Mut. Ins. Co., 213 AD2d 1030 (1995)]), defendant interposed only a claims adjuster’s assertion that defendant had “made the determination that the claimant was eligible for Workers’ Compensation” which in turn was based solely on an employer’s unsworn statement dated 18 months before the accident and a police accident report, offered for the first time in defendant’s reply papers below, which will not be considered by this Court (e.g. Johnston v Continental Broker-Dealer Corp., 287 AD2d 546 [2001]; Azzopardi v American Blower Corp., 192 AD2d 453 [1993]). Thus, defendant’s claim that assignor acted in the course of his employment at the time of the accident was “mere speculation” (Anarumo v Terminal Constr. Corp., 143 AD2d 616, 617 [1988]) and failed to establish any issues of fact regarding Workers’ Compensation coverage that must be resolved by the Board (see Lanpont, 244 AD2d at 210 [“Workers’ Compensation defense” successfully interposed where “(s)ufficient facts appear in the record to demonstrate the (defense’s) potential merit”]). Accordingly, the order below should be modified to grant plaintiffs summary judgment and the matter remanded to the court below for a calculation of the statutory interest and an assessment of attorney’s fees as authorized by Insurance Law § 5106 (a) and the regulations promulgated thereunder.
Decision Date: June 09, 2005

Legal questions (2)

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.

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: The insurer did not show that workers' compensation may apply; no referral, and the defense fails

Held the insurer failed to show the potential merit of its workers' compensation defense, offering only an adjuster's conclusion based on an old unsworn employer statement against sworn denials that the assignor was working, so the providers got summary judgment.

  • 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, 10 (this one included) are in the same category.

Claimant's prima facie case on motions

Open the full map

On summary judgment or another pretrial motion, what must a no-fault claimant show to establish its prima facie case?

This decision: Claimant's proof held to make out its prima facie case (rules on the question, but another ground decided the case)

Held the providers established prima facie entitlement by proof that they submitted claim forms stating the fact and amount of loss and that payment was overdue, shifting the burden to the insurer.

  • Court of AppealsCt App 2
  • Appellate DivisionApp Div 81
  • Appellate TermApp Term 843
  • Trial courtsTrial 139
2015, Court of Appeals: 1 decision (1 Proof sufficient)2007, Court of Appeals: 1 decision (1 Proof sufficient)2022, Appellate Division: 1 decision (1 Proof sufficient)2019, Appellate Division: 1 decision (1 Proof sufficient)2014, Appellate Division: 10 decisions (9 Proof sufficient, 1 Overdue not shown)2013, Appellate Division: 2 decisions (2 Proof sufficient)2012, Appellate Division: 2 decisions (2 Proof sufficient)2011, Appellate Division: 11 decisions (11 Proof sufficient)2010, Appellate Division: 3 decisions (2 Proof sufficient, 1 Overdue not shown)2009, Appellate Division: 3 decisions (2 Proof sufficient, 1 Other element missing)2008, Appellate Division: 8 decisions (6 Proof sufficient, 1 Overdue not shown, 1 Business-record foundation lacking)2007, Appellate Division: 16 decisions (13 Proof sufficient, 2 Mailing/receipt not shown, 1 Overdue not shown)2006, Appellate Division: 5 decisions (3 Proof sufficient, 1 Mailing/receipt not shown, 1 Other element missing)2005, Appellate Division: 5 decisions (5 Proof sufficient)2004, Appellate Division: 11 decisions (10 Proof sufficient, 1 Overdue not shown)2026, Appellate Division: 1 decision (1 Proof sufficient)2003, Appellate Division: 2 decisions (1 Proof sufficient, 1 Overdue not shown)2022, Appellate Term: 14 decisions (2 Mailing/receipt not shown, 12 Overdue not shown)2021, Appellate Term: 5 decisions (1 Proof sufficient, 4 Overdue not shown)2020, Appellate Term: 13 decisions (13 Overdue not shown)2019, Appellate Term: 23 decisions (22 Overdue not shown, 1 Other element missing)2018, Appellate Term: 26 decisions (3 Proof sufficient, 1 Mailing/receipt not shown, 22 Overdue not shown)2017, Appellate Term: 38 decisions (3 Proof sufficient, 1 Mailing/receipt not shown, 34 Overdue not shown)2016, Appellate Term: 41 decisions (7 Proof sufficient, 34 Overdue not shown)2015, Appellate Term: 44 decisions (12 Proof sufficient, 1 Mailing/receipt not shown, 30 Overdue not shown, 1 Business-record foundation lacking)2014, Appellate Term: 22 decisions (10 Proof sufficient, 12 Overdue not shown)2013, Appellate Term: 34 decisions (17 Proof sufficient, 11 Overdue not shown, 6 Business-record foundation lacking)2012, Appellate Term: 32 decisions (3 Proof sufficient, 2 Mailing/receipt not shown, 11 Overdue not shown, 16 Business-record foundation lacking)2011, Appellate Term: 29 decisions (6 Proof sufficient, 1 Mailing/receipt not shown, 13 Overdue not shown, 9 Business-record foundation lacking)2010, Appellate Term: 36 decisions (22 Proof sufficient, 3 Mailing/receipt not shown, 10 Business-record foundation lacking, 1 Other element missing)2009, Appellate Term: 52 decisions (28 Proof sufficient, 3 Mailing/receipt not shown, 21 Business-record foundation lacking)2008, Appellate Term: 49 decisions (16 Proof sufficient, 1 Mailing/receipt not shown, 32 Business-record foundation lacking)2007, Appellate Term: 104 decisions (8 Proof sufficient, 2 Mailing/receipt not shown, 94 Business-record foundation lacking)2006, Appellate Term: 112 decisions (76 Proof sufficient, 26 Mailing/receipt not shown, 1 Overdue not shown, 6 Business-record foundation lacking, 3 Other element missing)2005, Appellate Term: 90 decisions (84 Proof sufficient, 5 Mailing/receipt not shown, 1 Overdue not shown)2004, Appellate Term: 57 decisions (43 Proof sufficient, 10 Mailing/receipt not shown, 4 Other element missing)2003, Appellate Term: 7 decisions (7 Proof sufficient)2023, Appellate Term: 3 decisions (3 Overdue not shown)2024, Appellate Term: 7 decisions (1 Mailing/receipt not shown, 6 Overdue not shown)2025, Appellate Term: 3 decisions (1 Proof sufficient, 1 Mailing/receipt not shown, 1 Overdue not shown)2026, Appellate Term: 2 decisions (2 Mailing/receipt not shown)2023, Trial courts: 2 decisions (2 Proof sufficient)2022, Trial courts: 4 decisions (2 Proof sufficient, 2 Overdue not shown)2021, Trial courts: 11 decisions (6 Proof sufficient, 2 Mailing/receipt not shown, 2 Overdue not shown, 1 Other element missing)2020, Trial courts: 5 decisions (3 Proof sufficient, 1 Overdue not shown, 1 Other element missing)2019, Trial courts: 6 decisions (5 Proof sufficient, 1 Mailing/receipt not shown)2018, Trial courts: 2 decisions (2 Overdue not shown)2017, Trial courts: 3 decisions (1 Proof sufficient, 1 Overdue not shown, 1 Other element missing)2016, Trial courts: 4 decisions (4 Proof sufficient)2013, Trial courts: 1 decision (1 Proof sufficient)2012, Trial courts: 5 decisions (4 Proof sufficient, 1 Business-record foundation lacking)2011, Trial courts: 3 decisions (2 Proof sufficient, 1 Business-record foundation lacking)2010, Trial courts: 3 decisions (2 Proof sufficient, 1 Business-record foundation lacking)2009, Trial courts: 7 decisions (7 Proof sufficient)2008, Trial courts: 14 decisions (8 Proof sufficient, 1 Mailing/receipt not shown, 1 Overdue not shown, 4 Business-record foundation lacking)2007, Trial courts: 7 decisions (5 Proof sufficient, 2 Business-record foundation lacking)2006, Trial courts: 16 decisions (13 Proof sufficient, 2 Overdue not shown, 1 Other element missing)2005, Trial courts: 22 decisions (14 Proof sufficient, 5 Mailing/receipt not shown, 3 Business-record foundation lacking)2004, Trial courts: 15 decisions (9 Proof sufficient, 2 Mailing/receipt not shown, 4 Other element missing)2025, Trial courts: 2 decisions (1 Proof sufficient, 1 Mailing/receipt not shown)2026, Trial courts: 4 decisions (3 Proof sufficient, 1 Mailing/receipt not shown)2014, Trial courts: 1 decision (1 Proof sufficient)2015, Trial courts: 1 decision (1 Proof sufficient)2024, Trial courts: 1 decision (1 Proof sufficient)This decision
20052010201520202025
Proof sufficientMailing/receipt not shownOverdue not shownBusiness-record foundation lackingOther element missingThis decisionCites it or cited by itCited or followed

Of the 1,065 decisions on this question in the Second Department courts and the Court of Appeals, 513 (this one included) are in the same category.

Cited in this decision

  • Mary Immaculate Hosp. v Allstate Ins. Co. (2004 NY Slip Op 02359)The hospitals established entitlement to summary judgment by proving that statutory billing forms were mailed and received and payment was overdue.

Cited by

A label shows how the later decision treated this one.

  • A.B. Med. Servs., PLLC v American Tr. Ins. Co. (2009 NY Slip Op 29271) Contrasted (cf., but see)The insurer's proof raised a factual question about the assignor's employment status that required Workers' Compensation Board resolution.
  • B.Y., M.D., P.C. v Global Liberty Ins. Co. of N.Y. (2012 NY Slip Op 50156(U)) Contrasted (cf., but see)The insurer's proof raised a factual question about the assignor's employment status that required Workers' Compensation Board resolution.
  • Central Radiology Servs., P.C. v First Am. Ins. (2013 NY Slip Op 51031(U)) FollowedThe insurer submitted to personal jurisdiction by seeking default vacatur and leave to defend on the merits without a jurisdictional objection.
  • Chiropractic Testing Servs. of N.Y., P.C. v American Tr. Ins. Co. (2018 NY Slip Op 28052) FollowedA no-fault insurer seeking a stay for a workers' compensation determination need show only potential merit to its coverage claim.
  • American Tr. Ins. Co. v North Shore Family Chiropractic PC (2023 NY Slip Op 50208(U)) FollowedThe insurer's police report did not require referral of its course-of-employment defense to the Workers' Compensation Board.
  • Corona Comprehensive Med. Care, P.C. v Global Liberty Ins. Co. of N.Y. (2009 NY Slip Op 51432(U)) FollowedA workers' compensation defense is a statutory offset subject to preclusion unless timely raised in a denial.
  • American Tr. Ins. Co. v Nexray Med. Imaging PC (2023 NY Slip Op 50953(U))The insurer's petition to vacate a master arbitration award was denied because it submitted an award from a different arbitration.

Similar decisions

  • 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.
  • B.Y., M.D., P.C. v American Tr. Ins. Co. (2010 NY Slip Op 51902(U))The insurer's proof raised a factual question about employment at the time of the accident for the Workers' Compensation Board to resolve first.
  • 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.
  • A.B. Med. Servs. PLLC v Prudential Prop. & Cas. Ins. Co. (2005 NY Slip Op 50076(U))The insurer's affidavit and EUO evidence raised a triable coverage issue despite untimely denials of certain claims.
  • A.B. Med. Servs. PLLC v Encompass Ins. (2005 NY Slip Op 51892(U))Transportation benefits are nonassignable under the revised no-fault regulations for claims submitted on or after April 5, 2002.
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