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October 13, 2016

Matter of Unitrin Advantage Ins. Co. Kemper A. Unitrin Bus. v Professional Health Radiology (2016 NY Slip Op 06767)

https://www.beynensonlaw.com/case-law/matter-of-unitrin-advantage-ins-co-kemper-a-unitrin-bus-v-professionalhealth-radiology-2016-ny-slip-op-06767/

Court
Appellate Division, First Department
Decided
October 13, 2016
Citation
2016 NY Slip Op 06767 · 143 AD3d 536
Posture
Article 75 petition
Outcome
Provider prevailed
Later treatment
Followed in 1 later decision (see Cited by)
Issues
IME no-show CPLR article 75 (arbitration awards) Interest and attorney fees
Legal questions
No-show defense: insurer's proof (see the maps)
Cite as
Matter of Unitrin Advantage Ins. Co. Kemper A. Unitrin Bus. v Professional Health Radiology, 143 AD3d 536 (1st Dept 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 insurer failed to establish that its IME letters contained the required notice of reimbursement for lost earnings and transportation. Under 11 NYCRR 65-3.5 (e), that notice must accompany scheduling. The Appellate Division, First Department, upheld confirmation of two master arbitration awards because the insurer did not establish its IME no-show defense or grounds for a new arbitration hearing. Under Insurance Law § 5106 (a) and 11 NYCRR 65-4.10 (j) (4), the provider was entitled to court-fixed attorney fees for judicial review. The court modified one order to grant the fee counterclaim and remitted for determination of fees. The other fee denial remained undisturbed because the provider had not cross-appealed it; that order was affirmed insofar as appealed from.

Reported in New York Official Reports at Matter of Unitrin Advantage Ins. Co. Kemper A. Unitrin Bus. v Professional Health Radiology (2016 NY Slip Op 06767)

Matter of Unitrin Advantage Ins. Co. Kemper A. Unitrin Bus. v Professional Health Radiology
2016 NY Slip Op 06767 [143 AD3d 536]
October 13, 2016
Appellate Division, First Department
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
As corrected through Wednesday, December 7, 2016

[*1]

 In the Matter of Unitrin Advantage Insurance Company Kemper A. Unitrin Business, Appellant-Respondent,
v
Professional Health Radiology, as Assignee of Anggi Camacho, Appellant. Unitrin Advantage Insurance Company Kemper A. Unitrin Business, Appellant, v Professional Health Radiology, as Assignee of Nestor Camacho, Respondent.

Gullo & Associates, LLC, Brooklyn (Cristina Carollo of counsel), for appellant-respondent/appellant.

Gary Tsirelman, P.C., Brooklyn (David M. Gottlieb and Stefan Belinfanti of counsel), for respondent-appellant/respondent.

Order, Supreme Court, New York County (Melvin L. Schweitzer, J.), entered January 29, 2014, which, to the extent appealed from as limited by the briefs, denied and dismissed petitioner Unitrin’s petition to vacate a no-fault master arbitration award dated June 3, 2013, and granted respondent Professional Health Radiology as assignee of Nestor Camacho’s counterclaim to the extent of confirming the award, unanimously affirmed, without costs. Order, same court (Lawrence K. Marks, J.), entered March 14, 2014, which denied Unitrin’s petition to vacate a no-fault master arbitration award dated June 3, 2013, granted respondent Professional Health Radiology as assignee of Anggi Camacho’s counterclaim to confirm the award, and denied Professional Health’s counterclaim for attorney’s fees in connection with the court proceeding, unanimously modified, on the law, to grant the counterclaim for attorney’s fees, and remand the matter to Supreme Court for further proceedings consistent with this decision, and otherwise affirmed, without costs.

Unitrin failed to establish that it was entitled to deny Professional Health’s claims on the ground that Professional Health’s assignors, Nestor Camacho and Anggi Camacho, did not appear for independent medical examinations (IMEs) (see American Tr. Ins. Co. v Clark, 131 AD3d 840 [1st Dept 2015]). The no-fault regulations include mandatory notice requirements governing insurer requests for both IMEs and examinations under oath (11 NYCRR 65-3.5 [e]). The regulations expressly provide that the insurer “shall inform the applicant at the time the examination is scheduled that the applicant will be reimbursed for any loss of earnings and reasonable transportation expenses incurred in complying with the request” (id.). Unitrin failed to establish that the requisite regulatory language was contained within its November 30, 2011 letters sent to the assignors, and, based on the multiple errors committed by Unitrin, it failed to establish inadvertent law office error, or that the cases should be remanded, in the interest of justice, for a new arbitration hearing.

[*2] Pursuant to Insurance Law § 5106 (a), if a valid claim or portion of a claim for no-fault benefits is overdue, “the claimant shall also be entitled to recover his attorney’s reasonable fee, for services necessarily performed in connection with securing payment of the overdue claim, subject to [the] limitations promulgated by the superintendent in regulations.” “In a proceeding for judicial review of an award by a master arbitrator, an attorney’s fee shall be fixed by the court adjudicating the matter” (Matter of GEICO Ins. Co. v AAAMG Leasing Corp., 139 AD3d 947, 948 [2d Dept 2016]; see 11 NYCRR 65-4.10 [j] [4]). Professional Health, therefore, is entitled to attorney’s fees in connection with the Supreme Court proceeding regarding Anggi Camacho, and we remand the matter for further proceedings to determine those fees. Professional Health did not file a cross appeal with respect to the denial of its counterclaim for attorney’s fees in connection with the Supreme Court proceeding regarding Nestor Camacho, and this Court lacks the power to grant the counterclaim (see Hecht v City of New York, 60 NY2d 57 [1983]). Concur—Renwick, J.P., Manzanet-Daniels, Gische and Webber, JJ.

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 (rules on the question, but another ground decided the case)

Held the insurer not entitled to deny the claims for IME nonappearance because it failed to show its scheduling letters contained the mandatory notice of reimbursement for lost earnings and transportation expenses.

  • Appellate DivisionApp Div 52
  • Appellate TermApp Term 71
  • Trial courtsTrial 40
2023, Appellate Division: 4 decisions (3 Defense proved, 1 Requests not compliant)2022, Appellate Division: 8 decisions (3 Defense proved, 5 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: 5 decisions (3 Defense proved, 1 Nonappearance not proved, 1 Requests not compliant)2015, Appellate Division: 7 decisions (2 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)2006, Appellate Term: 2 decisions (1 Requests not compliant, 1 Triable issue)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 followed

Of the 163 decisions on this question in the First Department courts and the Court of Appeals, 39 (this one included) are in the same category. One decision in other departments that cites or is cited by this one is on the full map.

Cited in this decision

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

  • American Tr. Ins. Co. v Clark (2015 NY Slip Op 06759) FollowedThe insurer failed to establish that the assignor's IMEs were scheduled within the 30-day period required by 11 NYCRR 65-3.5 (d).
  • Matter of GEICO Ins. Co. v AAAMG Leasing Corp. (2016 NY Slip Op 03879) FollowedA provider's attorney's fee for judicial review of a master arbitration award is fixed by the court under 11 NYCRR 65-4.10 (j) (4).

Cited by

A label shows how the later decision treated this one.

  • Body Acupuncture Care, P.C. v Erie Ins. Co. of N.Y. (2018 NY Slip Op 51362(U)) FollowedThe insurer's IME notice failed to plainly advise the assignor of reimbursement for lost earnings and reasonable transportation costs.
  • Matter of Country-Wide Ins. Co. v TC Acupuncture P.C. (2019 NY Slip Op 04087)Attorney fees for judicial review of a master arbitration award are fixed by the court under 11 NYCRR 65-4.10 (j) (4).

Similar decisions

  • American Tr. Ins. Co. v Beach Med. Rehabilitation, P.C. (2026 NY Slip Op 03771)The insurer failed to raise a triable issue on timely denials or causation in its action for de novo review of no-fault claims.
  • Matter of American Tr. Ins. Co. v Smart Choice Med., P.C. (2023 NY Slip Op 03191)An injured claimant's failure to attend requested IMEs breaches a condition precedent and vitiates no-fault coverage.
  • Matter of American Tr. Ins. Co. v Community Med. Imaging, P.C. (2026 NY Slip Op 01351)The provider's attorney fee award was reversed because neither the order nor the record explained its amount.
  • Matter of American Tr. Ins. Co. v Stand Up MRI of Manhattan (2026 NY Slip Op 01353)The provider's $300 attorney fee award was affirmed because it supplied no description of counsel's work or time and requested no hearing.
  • Matter of American Tr. Ins. Co. v Patient Care Assoc. (2026 NY Slip Op 01783)A master arbitration award must be confirmed when the court denies a petition to vacate it.
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