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May 10, 2022

Country-Wide Ins. Co. v Delacruz (2022 NY Slip Op 03068)

https://www.beynensonlaw.com/case-law/country-wide-ins-co-v-delacruz-2022-ny-slip-op-03068/

Court
Appellate Division, First Department
Decided
May 10, 2022
Citation
2022 NY Slip Op 03068 · 205 AD3d 473
Posture
Summary judgment
Outcome
Provider prevailed
Earlier history
Appeal from Country-Wide Ins. Co. v Delacruz (2021 NY Slip Op 21019) (Affirmed)
Later treatment
Declined to follow in 1, contrasted (cf., but see) in 1 and followed in 4 later decisions (see Cited by)
Issues
EUO no-show Discovery and procedure
Legal questions
No-show defense: insurer's proof (see the maps)
Cite as
Country-Wide Ins. Co. v Delacruz, 205 AD3d 473 (1st Dept 2022)

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's EUO nonappearance motion was premature because it withheld the specific objective justification for requesting the EUO. The Appellate Division, First Department, affirmed denial of summary judgment against the providers under CPLR 3212 (f). The justification was essential to opposing the motion, lay exclusively within the insurer's control, and remained undisclosed despite discovery demands. Without it, the insurer could not establish compliance with 11 NYCRR 65-3.5 (e). The providers did not waive their objection by failing to challenge the notices when received: the notices gave no justification, and the regulation set no objection deadline.

Reported in New York Official Reports at Country-Wide Ins. Co. v Delacruz (2022 NY Slip Op 03068)

Country-Wide Ins. Co. v Delacruz
2022 NY Slip Op 03068 [205 AD3d 473]
May 10, 2022
Appellate Division, First Department
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
As corrected through Wednesday, June 29, 2022

[*1]

 Country-Wide Insurance Company, Appellant,
v
Jeffrey Delacruz et al., Defendants, and Healthway Medical Care P.C. et al., Respondents.

Thomas Torto, New York, for appellant.

The Rybak Firm, PLLC, Brooklyn (Maksim Leyvi of counsel), for respondents.

Order, Supreme Court, New York County (Gerald Lebovits, J.), entered on or about February 4, 2021, which denied plaintiff’s motion for summary judgment as against defendants Healthway Medical Care P.C., Acupuncture Now P.C., SB Chiropractic, P.C., and Jules Francois Parisien MD, unanimously affirmed, without costs.

This appeal concerns plaintiff Country-Wide Insurance Company’s potential obligation to pay no-fault insurance benefits. Defendant Jeffrey Delacruz was the driver of a vehicle that was involved in a collision. The vehicle was covered by a no-fault insurance policy issued by Country-Wide. Delacruz assigned his right to collect no-fault benefits under that policy to his treating medical providers. Those providers applied for no-fault benefits from Country-Wide but were denied.

Country-Wide then brought this action for a declaratory judgment that it is not required to pay no-fault benefits to Delacruz or to the other defendants (all medical-provider assignees of Delacruz). Country-Wide moved for summary judgment on the ground that Delacruz’s failure to appear for scheduled examinations under oath (EUOs) defeats coverage under the no-fault policy, and thus forecloses the medical providers’ claim to benefits.

The court properly denied plaintiff’s motion for summary judgment as premature (see CPLR 3212 [f]). Plaintiff failed to provide a specific objective justification for requesting the examination under oath (EUO). Plaintiff’s reason for the EUO is essential for defendants to oppose plaintiff’s summary judgment motion and this fact is exclusively within the knowledge and control of the movant (11 NYCRR 65-3.5 [e]; see Kemper Independence Ins. Co. v AB Med. Supply, Inc., 187 AD3d 671, 671 [1st Dept 2020]; American Tr. Ins. Co. v Jaga Med. Servs., P.C., 128 AD3d 441, 441 [1st Dept 2015]; cf. Allstate Ins. Co. v Pierre, 123 AD3d 618 [1st Dept 2014]; Interboro Ins. Co. v Clennon, 113 AD3d 596, 597 [2d Dept 2014]). Further, plaintiff concedes that it provided no response to defendants’ discovery demands for the “specific objective justification” for its request that the injured claimant submit to an EUO.

We have considered and reject all of plaintiff’s arguments that it is not required to provide claimants with the reason it requested the EUO. An insurer must affirmatively establish that it complied with the strict no-fault insurance claim procedures set forth in 11 NYCRR 65-3.5 (see generally PV Holding Corp. v Hank Ross Med., P.C., 188 AD3d 429, 430 [1st Dept 2020]). In the absence of any justification for the EUO, plaintiff has failed to establish, as a matter of law, that it complied with the governing regulations (11 NYCRR 65-3.5 [e]; AB Med. Supply at 671; Jaga Med. Servs. at 441; see also American Tr. Ins. Co. v Curry, 45 Misc 3d 171, 174-175 [Sup Ct, NY County 2013]).

The court properly rejected plaintiff’s contention that defendants waived any claim as to the reasonableness of the EUO notices by failing to object upon receipt. [*2]In its EUO notices, plaintiff provided no justification for these defendants to object to. In any event, the regulation does not require defendants to lodge any objection to the justification within a specific timeframe. Westchester County Med. Ctr. v New York Cent. Mut. Fire Ins. Co. (262 AD2d 553, 555 [2d Dept 1999]) is inapposite. Concur—Renwick, J.P., Mazzarelli, Gesmer, González, JJ. [Prior Case History: 71 Misc 3d 247.]

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 did not show its requests met the regulatory timing, follow-up or justification requirements

Held summary judgment premature because the insurer never disclosed a specific objective justification for the EUO, so it did not establish compliance with the regulations, and the providers did not waive the point by not objecting.

  • Appellate DivisionApp Div 48
  • Appellate TermApp Term 69
  • Trial courtsTrial 40
2023, Appellate Division: 4 decisions (3 Defense proved, 1 Requests not compliant)2022, Appellate Division: 7 decisions (3 Defense proved, 4 Requests not compliant)2021, Appellate Division: 2 decisions (2 Defense proved)2020, Appellate Division: 4 decisions (3 Defense proved, 1 Requests not compliant)2019, Appellate Division: 3 decisions (1 Defense proved, 1 Mailing not proved, 1 Requests not compliant)2018, Appellate Division: 5 decisions (2 Defense proved, 1 Mailing not proved, 2 Requests not compliant)2017, Appellate Division: 2 decisions (1 Defense proved, 1 Requests not compliant)2016, Appellate Division: 3 decisions (1 Defense proved, 1 Nonappearance not proved, 1 Requests not compliant)2015, Appellate Division: 6 decisions (1 Defense proved, 5 Requests not compliant)2014, Appellate Division: 2 decisions (2 Defense proved)2013, Appellate Division: 4 decisions (3 Defense proved, 1 Mailing not proved)2011, Appellate Division: 1 decision (1 Defense proved)2024, Appellate Division: 2 decisions (2 Defense proved)2025, Appellate Division: 3 decisions (2 Defense proved, 1 Requests not compliant)2019, Appellate Term: 3 decisions (1 Mailing not proved, 1 Nonappearance not proved, 1 Triable issue)2018, Appellate Term: 1 decision (1 Defense proved)2017, Appellate Term: 1 decision (1 Nonappearance not proved)2016, Appellate Term: 14 decisions (5 Defense proved, 6 Nonappearance not proved, 1 Requests not compliant, 2 Triable issue)2015, Appellate Term: 12 decisions (11 Defense proved, 1 Requests not compliant)2014, Appellate Term: 6 decisions (6 Defense proved)2013, Appellate Term: 5 decisions (4 Defense proved, 1 Mailing not proved)2012, Appellate Term: 8 decisions (6 Defense proved, 2 Mailing not proved)2011, Appellate Term: 7 decisions (6 Defense proved, 1 Mailing not proved)2010, Appellate Term: 2 decisions (2 Defense proved)2007, Appellate Term: 1 decision (1 Requests not compliant)2005, Appellate Term: 3 decisions (1 Defense proved, 2 Requests not compliant)2025, Appellate Term: 3 decisions (3 Defense proved)2026, Appellate Term: 2 decisions (2 Defense proved)2020, Appellate Term: 1 decision (1 Mailing not proved)2022, Trial courts: 8 decisions (2 Defense proved, 1 Mailing not proved, 1 Nonappearance not proved, 4 Requests not compliant)2021, Trial courts: 6 decisions (3 Defense proved, 2 Requests not compliant, 1 No-show excused)2020, Trial courts: 7 decisions (1 Mailing not proved, 6 Requests not compliant)2019, Trial courts: 1 decision (1 Defense proved)2018, Trial courts: 2 decisions (1 Defense proved, 1 Requests not compliant)2015, Trial courts: 1 decision (1 Defense proved)2014, Trial courts: 3 decisions (2 Defense proved, 1 Nonappearance not proved)2013, Trial courts: 4 decisions (2 Defense proved, 2 Nonappearance not proved)2009, Trial courts: 1 decision (1 Defense proved)2007, Trial courts: 1 decision (1 Requests not compliant)2024, Trial courts: 1 decision (1 Requests not compliant)2025, Trial courts: 2 decisions (1 Mailing not proved, 1 Nonappearance not proved)2026, Trial courts: 1 decision (1 Mailing not proved)2005, Trial courts: 1 decision (1 Defense proved)2023, 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 followedDistinguished or limited

Of the 157 decisions on this question in the First Department courts and the Court of Appeals, 37 (this one included) are in the same category. 2 decisions in other departments that cite or are cited by this one are on the full map.

Cited in this decision

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

  • Kemper Independence Ins. Co. v AB Med. Supply, Inc. (2020 NY Slip Op 06209) FollowedThe insurer's summary judgment motion was premature because its objective basis for requesting an EUO was unavailable to the providers.
  • American Tr. Ins. Co. v Jaga Med. Servs., P.C. (2015 NY Slip Op 03925) FollowedThe insurer's summary judgment motion based on the claimant's EUO nonappearance was denied because essential discovery remained outstanding.
  • Allstate Ins. Co. v Pierre (2014 NY Slip Op 08921) Contrasted (cf., but see)Failure to attend requested EUOs breaches a no-fault coverage condition, regardless of denial timeliness or willfulness.
  • Interboro Ins. Co. v Clennon (2014 NY Slip Op 00092) Contrasted (cf., but see)The assignor's two EUO nonappearances supported a declaration that the providers were not entitled to no-fault benefits.
  • American Tr. Ins. Co. v Curry (2013 NY Slip Op 23470)The insurer failed to justify its EUO request or offer admissible proof of the injured claimant's nonappearance.
  • Country-Wide Ins. Co. v Delacruz (2021 NY Slip Op 21019) AffirmedThe insurer's EUO no-show summary judgment motion failed for missing timeliness proof and outstanding discovery into justification.

Cited by

A label shows how the later decision treated this one.

  • Flatbush Acupuncture P.C. v Repwest Ins. Co. (2025 NY Slip Op 25032) Declined to followAn insurer in the Second Department need not disclose its objective justification for an EUO to obtain summary judgment for nonappearance.
  • Liberty Mut. Ins. Co. v Mercado (2025 NY Slip Op 00631) Contrasted (cf., but see)The insurers established an objective justification for EUOs and timely requests that the injured claimants failed to attend.
  • Country-Wide Ins. Co. v Alicea (2023 NY Slip Op 01474) FollowedAn insurer's EUO nonappearance summary judgment motion is premature without disclosure of its objective justification for requesting the EUO. The insurer obtained a declaration that it owed no benefits and a permanent stay of further actions involving the injured claimant.
  • State Farm Mut. Auto. Ins. Co. v Lifeline Med. Imaging, P.C. (2025 NY Slip Op 02025) FollowedThe insurers' EUO-based summary judgment motion was premature because they had not disclosed their objective justification for the EUOs. The insurers sought a declaration of no obligation to pay the provider's bills, alleging nonappearance and refusal to produce a knowledgeable individual.
  • Kim v State Farm Ins. Co. (2024 NY Slip Op 51364(U)) FollowedThe insurer's EUO letters failed to give a specific objective justification tied to the claim, defeating summary judgment for nonappearance.
  • Country-Wide Ins. Co. v Henderson (2022 NY Slip Op 51304(U)) FollowedThe insurer failed to document a consistent objective justification for its EUO request, and its summary judgment motion was premature.
  • State Farm Mut. Auto. Ins. Co. v Emote Med. Servs., P.C. (2022 NY Slip Op 50818(U))The insurers' default-judgment motion failed for lack of proof that the provider's EUOs were timely and properly requested.

Similar decisions

  • NY Wellness Med., P.C. v Nationwide Mut. Ins. Co. (2022 NY Slip Op 50359(U))An insurer need not set forth objective reasons for requesting EUOs to establish prima facie entitlement to summary judgment.
  • Quality Health Supply Corp. v Nationwide Ins. (2023 NY Slip Op 02689)The insurer established timely EUO notices and denials, proper follow-up, and the assignor's nonappearances.
  • Arco Med. N.Y., P.C. v Lancer Ins. Co. (2012 NY Slip Op 22278)An insurer may schedule an EUO outside the applicant's county if the place and time are reasonably convenient.
  • MDJ Med. PC v Delos Ins. Co. (2016 NY Slip Op 50604(U))The insurer established timely EUO requests, proper mailing and the assignor's nonappearance at two scheduled EUOs. Its EUO letters demonstrated compliance with the request periods in 11 NYCRR 65-3.5 (b) and 65-3.6 (b).
  • MUA Chiropractic Healthcare, PLLC v Nationwide Mut. Ins. Co. (2022 NY Slip Op 51384(U))An insurer need not state objective reasons for provider EUOs to establish prima facie entitlement to summary judgment for nonappearance.
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