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October 30, 2020

BR Clinton Chiropractic, P.C. v GEICO Ins. Co. (2020 NY Slip Op 20291)

https://www.beynensonlaw.com/case-law/br-clinton-chiropractic-p-c-v-geico-ins-co-2020-ny-slip-op-20291/

Court
Appellate Term, Second Department
Decided
October 30, 2020
Citation
2020 NY Slip Op 20291 · 70 Misc 3d 26
Posture
Summary judgment
Outcome
Provider prevailed
Issues
Fraudulent incorporation (Mallela) Discovery and procedure
Legal questions
Fraudulent incorporation (Mallela) (see the maps)
Cite as
BR Clinton Chiropractic, P.C. v GEICO Ins. Co., 70 Misc 3d 26 (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.

The provider could pursue claims for services rendered before its sole shareholder's chiropractic license was revoked. The Appellate Term, Second Department, reversed and denied the insurer's motion, treated as one for summary judgment because it presented a purely legal question on undisputed facts under CPLR 3211 (c). Business Corporation Law §§ 1509 and 1510 require severance of a disqualified professional's ties and repurchase of the professional's shares, but those requirements are not self-executing. Although neither requirement was met, no forfeiture or dissolution had been sought, and the corporation continued to exist and could wind up its affairs. Its living shareholder retained administrative authority. Failure to repurchase the shares did not make otherwise valid contracts unenforceable or permit withholding payment for legally rendered services.

Reported in New York Official Reports at BR Clinton Chiropractic, P.C. v GEICO Ins. Co. (2020 NY Slip Op 20291)

BR Clinton Chiropractic, P.C. v GEICO Ins. Co.
2020 NY Slip Op 20291 [70 Misc 3d 26]
Accepted for Miscellaneous Reports Publication
Supreme Court, Appellate Term, Second Department, 2d, 11th and 13th Judicial Districts
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
As corrected through Wednesday, February 10, 2021

[*1]

BR Clinton Chiropractic, P.C., as Assignee of Sheila Carter, Appellant,
v
GEICO Ins. Co., Respondent.

Supreme Court, Appellate Term, Second Department, 2d, 11th and 13th Judicial Districts, October 30, 2020

APPEARANCES OF COUNSEL

Gary Tsirelman, P.C. (Selina Chin and David M. Gottlieb of counsel) for appellant.

Law Office of Goldstein, Flecker & Hopkins (Lawrence J. Chanice of counsel) for respondent.

{**70 Misc 3d at 27} OPINION OF THE COURT

Memorandum.

Ordered that the order is reversed, with $30 costs, and defendant’s motion for, in effect, summary judgment dismissing the complaint is denied.

In this action by a corporate provider to recover assigned first-party no-fault benefits for services rendered to plaintiff’s assignor in 2009, defendant moved for, in effect, summary judgment dismissing the complaint. Defendant argued that plaintiff professional corporation could not enforce its claims because its sole shareholder had been legally disqualified from rendering professional services upon the revocation of his chiropractic license on June 28, 2010. The Civil Court granted defendant’s motion.

Initially, it is noted that defendant’s motion to dismiss the complaint pursuant to CPLR 3211 was made after issue had been joined. Generally, such a motion must be made “before service of the responsive pleading is required” (CPLR 3211 [e]), although “[w]hether or not issue [*2]has been joined, the court, after adequate notice to the parties, may treat the motion as a motion for summary judgment” (CPLR 3211 [c]). While it is uncontested that the Civil Court did not notify the parties that it was treating the motion as one for summary judgment, an exception to the notice requirement is applicable here, as defendant’s motion exclusively involved “a purely legal question rather than any issues of fact” (Mihlovan v Grozavu, 72 NY2d 506, 508 [1988]; Four Seasons Hotels v Vinnik, 127 AD2d 310, 320 [1987]; Renelique v State-Wide Ins. Co., 50 Misc 3d 137[A], 2016 NY Slip Op 50095[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2016]). All the relevant facts are undisputed. Consequently, as the sole issue was the application of the Business Corporation Law, it was proper for the Civil Court to, in effect, treat defendant’s motion to dismiss as one for summary judgment “without first giving notice of its intention to do so” (Four Seasons Hotels, 127 AD2d at 320).

Pursuant to Business Corporation Law §§ 1509 and 1510, when professionals lose their license, they are required to sever{**70 Misc 3d at 28} their ties with the professional service corporation. If the professional does not sever those ties, section 1509 grants the professional service corporation the authority to force the professional to do so, and failure to enforce this requirement constitutes a ground for forfeiture of the professional service corporation’s certificate of incorporation and its dissolution. Section 1510, among other things, directs the professional service corporation to repurchase the professional’s shares within six months of his disqualification. None of these requirements is self-executing.

Here, the professional has not complied with section 1509 and the professional service corporation has not repurchased his shares pursuant to section 1510, so the professional remains the corporation’s sole shareholder. No one has moved for forfeiture of plaintiff’s certificate of incorporation or its dissolution. Despite revocation of its shareholder’s professional license, plaintiff continued to exist and is entitled to wind up its affairs and seek to recover no-fault benefits for the services it rendered to its assignor prior to June 28, 2010 (see A.B. Med. Servs., PLLC v National Grange Mut. Ins. Co., 34 Misc 3d 145[A], 2012 NY Slip Op 50154[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2012]; Kipor Medicine, P.C. v GEICO, 28 Misc 3d 129[A], 2010 NY Slip Op 51247[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2010]; see e.g. A.B. Med. Servs., PLLC v Travelers Indem. Co., 26 Misc 3d 69 [App Term, 2d Dept, 9th & 10th Jud Dists 2009]).

The case of Ocean Diagnostic Imaging, P.C. v Merchants Mut. Ins. Co. (15 Misc 3d 9 [App Term, 2d Dept, 2d & 11th Jud Dists 2007]) is distinguishable. In that case, the death of the doctor who was the sole officer, director and shareholder of a professional service corporation required the dismissal of its appeal because no one remained with authority to prosecute the action. Here, however, the sole shareholder is alive and continues to have authority to act for the professional corporation as “an administrator, whose role is to preserve the value of, and prevent loss to, the [professional service corporation]” (Eastern Star Acupuncture, P.C. v Allstate Ins. Co., 36 Misc 3d 41, 43 [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2012]), rather than as a member of the profession from which he has been barred.

[*3]

Section 1510 directs plaintiff to take actions that it concededly failed to do. It does not hold, however, that such a violation makes otherwise valid contracts unenforceable or that the{**70 Misc 3d at 29} corporation’s debtor should be entitled to withhold payment for services legally rendered. Consequently, there is no bar to plaintiff’s pursuit of reimbursement for services rendered to its assignor.

Accordingly, the order is reversed and defendant’s motion for, in effect, summary judgment dismissing the complaint is denied.

Aliotta, P.J., Siegal and Toussaint, JJ., concur.

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.

Fraudulent incorporation (Mallela)

Open the full map

On the merits, when may a no-fault insurer withhold payment because unlicensed persons own or control the provider (Mallela)?

This decision: Alleged conduct legally cannot support the ineligibility defense

Held that the sole shareholder's later license revocation, and the corporation's failure to make him sever ties or repurchase his shares under BCL 1509-1510, did not bar the still-existing corporation from recovering for services rendered before revocation.

  • Court of AppealsCt App 3
  • Appellate DivisionApp Div 8
  • Appellate TermApp Term 26
  • Trial courtsTrial 24
2019, Court of Appeals: 1 decision (1 Defense established)2005, Court of Appeals: 1 decision (1 Defense established)2025, Court of Appeals: 1 decision (1 Not a Mallela ground)2019, Appellate Division: 4 decisions (2 Defense established, 2 Defense not established)2017, Appellate Division: 2 decisions (1 Defense established, 1 Defense not established)2016, Appellate Division: 1 decision (1 Triable issue)2008, Appellate Division: 1 decision (1 Triable issue)2020, Appellate Term: 1 decision (1 Not a Mallela ground)2019, Appellate Term: 1 decision (1 Defense established)2013, Appellate Term: 1 decision (1 Defense established)2012, Appellate Term: 1 decision (1 Not a Mallela ground)2010, Appellate Term: 6 decisions (2 Defense established, 1 Triable issue, 2 Defense not established, 1 Not a Mallela ground)2009, Appellate Term: 4 decisions (2 Defense established, 1 Triable issue, 1 Not a Mallela ground)2008, Appellate Term: 4 decisions (1 Defense established, 1 Triable issue, 2 Defense not established)2007, Appellate Term: 5 decisions (1 Defense established, 4 Triable issue)2006, Appellate Term: 2 decisions (1 Triable issue, 1 Defense not established)2015, Appellate Term: 1 decision (1 Defense not established)2019, Trial courts: 1 decision (1 Triable issue)2017, Trial courts: 2 decisions (1 Defense not established, 1 Not a Mallela ground)2015, Trial courts: 2 decisions (1 Defense established, 1 Not a Mallela ground)2013, Trial courts: 1 decision (1 Defense not established)2010, Trial courts: 1 decision (1 Not a Mallela ground)2009, Trial courts: 3 decisions (1 Defense established, 2 Triable issue)2008, Trial courts: 4 decisions (1 Defense established, 2 Triable issue, 1 Defense not established)2007, Trial courts: 2 decisions (1 Defense established, 1 Triable issue)2006, Trial courts: 3 decisions (3 Triable issue)2005, Trial courts: 4 decisions (3 Defense established, 1 Defense not established)2004, Trial courts: 1 decision (1 Not a Mallela ground)This decision
20052010201520202025
Defense establishedTriable issueDefense not establishedNot a Mallela groundThis decisionCites it or cited by itCited or followed

Of the 61 decisions on this question in the Second Department courts and the Court of Appeals, 9 (this one included) are in the same category.

Cited in this decision

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

  • Renelique v State-Wide Ins. Co. (2016 NY Slip Op 50095(U))A default declaratory judgment precludes a no-fault recovery that would impair the rights established by that judgment.
  • A.B. Med. Servs., PLLC v National Grange Mut. Ins. Co. (2012 NY Slip Op 50154(U))A provider may wind up its affairs and recover no-fault benefits for services rendered before revocation of its owner's medical license.
  • Kipor Medicine, P.C. v GEICO (2010 NY Slip Op 51247(U))The insurer failed to support consolidation, amendment of its answer, and further discovery after the notice of trial.
  • A.B. Med. Servs., PLLC v Travelers Indem. Co. (2009 NY Slip Op 29510)A professional service LLC's disqualified sole member may wind up its affairs by prosecuting an action for benefits in the company's name.
  • Eastern Star Acupuncture, P.C. v Allstate Ins. Co. (2012 NY Slip Op 22029) FollowedA physician's estate administrator need not be medically licensed to authorize prosecution of the professional corporation's claims.

Similar decisions

  • BR Clinton Chiropractic, P.C. v New York Cent. Mut. Fire Ins. Co. (2012 NY Slip Op 51270(U))The provider and insurer failed to establish entitlement to summary judgment on the first through fifth causes of action.
  • Lexington Acupuncture, P.C. v State Farm Ins. Co. (2006 NY Slip Op 26251)The provider's summary judgment motion was premature because discovery could establish fraudulent incorporation and reimbursement ineligibility.
  • Multiquest, P.L.L.C. v Allstate Ins. Co. (2007 NY Slip Op 27366)A professional service limited liability company is ineligible for no-fault reimbursement if it violates licensing requirements.
  • AB Med., PLLC v Unitrin Advantage Ins. Co. (2011 NY Slip Op 52453(U))The insurer failed to show that discovery into the provider's current corporate status was material and necessary to its defense.
  • Midborough Acupuncture P.C. v State Farm Ins. Co. (2006 NY Slip Op 26360)An insurer's fraudulent-incorporation defense survives an untimely denial, and discovery into provider ownership and licensing is material.
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