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This article is part of our ongoing no-fault coverage, with 271 published articles analyzing no-fault issues across New York State. Attorney Jason Tenenbaum brings 24+ years of hands-on experience to this analysis, drawing from his work on more than 1,000 appeals, over 100,000 no-fault cases, and recovery of over $100 million for clients throughout Nassau County, Suffolk County, Queens, Brooklyn, Manhattan, and the Bronx. For personalized legal advice about how these principles apply to your specific situation, contact our Long Island office at (516) 750-0595 for a free consultation.
The New York no-fault insurance system relies heavily on accurate medical reporting to function properly. When healthcare providers submit fraudulent documentation, it undermines the entire system and can result in serious criminal consequences. The case of People v Palmeri demonstrates how courts handle physicians who deliberately falsify required insurance forms.
No-fault C-4 forms are critical documents that medical providers must complete accurately when treating patients injured in motor vehicle accidents. These forms require physicians to assess whether a patient is totally disabled or capable of working — determinations that directly impact insurance benefits and coverage decisions under New York No-Fault Insurance Law.
Jason Tenenbaum’s Analysis:
People v Palmeri (Michael), 2012 NY Slip Op 22040 (App. Term 2d Dept. 2012)
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It has just been an awful few months for the plaintiffs bar out there. First, many defacto owners of certain supply companies take guilty pleas, forfeit millions of dollars and end up with non-parolable 3-5 year sentences. Second, the feds in what appears to be the type of investigation known to stopping the Italian Mafia sends a well-deserved shock wave through our legal community. Now, a surgeon’s conviction for insurance fraud has been sustained. Just so you know, I am a month late on this one.
“The testimonies of the People’s witnesses appear truthful on their face, they are internally consistent as to material fact, and established that defendant knew, when he filled out the C-4 forms, that his patient was “working” within the meaning of question 7 on the form, and not “totally disabled” within the meaning of question 8 on the form. In so falsifying the C-4 forms, and filing said forms with the Board, defendant offered false instruments for filing in the second degree and committed insurance fraud in the fifth degree and petit larceny.”
Key Takeaway
The Palmeri case highlights the serious consequences medical providers face when they knowingly submit false information on no-fault insurance forms. Courts will uphold fraud convictions when witness testimony consistently demonstrates that a physician deliberately misrepresented a patient’s work capacity, emphasizing that knowledge is quite a broad term in insurance fraud prosecutions.
Legal Update (February 2026): Since this post’s publication, New York’s no-fault insurance regulations, fraud investigation procedures, and penalty structures for healthcare provider violations may have undergone significant amendments. Practitioners should verify current Insurance Law provisions, updated C-4 form requirements, and any revised fraud enforcement protocols that may affect liability and penalties for medical providers in the no-fault system.
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Legal Context
Why This Matters for Your Case
New York's no-fault insurance system, established under Insurance Law Article 51, is one of the most complex insurance frameworks in the country. Every motorist must carry Personal Injury Protection coverage that pays medical expenses and lost wages regardless of fault, up to $50,000 per person.
But insurers routinely deny valid claims using peer reviews, EUO scheduling tactics, fee schedule reductions, and coverage defenses. The Law Office of Jason Tenenbaum has handled over 100,000 no-fault cases since 2002 — from initial claim submissions through arbitration before the American Arbitration Association, trials in Civil Court and Supreme Court, and appeals to the Appellate Term and Appellate Division. Jason Tenenbaum is one of the few attorneys in the state who both writes his own appellate briefs and tries his own cases.
His 2,353+ published legal articles on no-fault practice are cited by attorneys throughout New York. Whether you are dealing with a medical necessity denial, an EUO no-show defense, a fee schedule dispute, or a coverage question, this article provides the kind of detailed case-law analysis that helps practitioners and claimants understand exactly where the law stands.
About This Topic
New York No-Fault Insurance Law
New York's no-fault insurance system requires every driver to carry Personal Injury Protection (PIP) coverage that pays medical expenses and lost wages regardless of who caused the accident. But insurers routinely deny, delay, and underpay valid claims — using peer reviews, IME no-shows, and fee schedule defenses to avoid paying providers and injured claimants. Attorney Jason Tenenbaum has litigated thousands of no-fault arbitrations and court cases since 2002.
271 published articles in No-Fault
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Disclaimer: This article is published by the Law Office of Jason Tenenbaum, P.C. for informational and educational purposes only. It does not constitute legal advice, and no attorney-client relationship is formed by reading this content. The legal principles discussed may not apply to your specific situation, and the law may have changed since this article was last updated.
New York law varies by jurisdiction — court decisions in one Appellate Division department may not be followed in another, and local court rules in Nassau County Supreme Court differ from those in Suffolk County Supreme Court, Kings County Civil Court, or Queens County Supreme Court. The Appellate Division, Second Department (which covers Long Island, Brooklyn, Queens, and Staten Island) and the Appellate Term (which hears appeals from lower courts) each have distinct procedural requirements and precedents that affect litigation strategy.
If you need legal help with a no-fault matter, contact our office at (516) 750-0595 for a free consultation. We serve clients throughout Long Island (Huntington, Babylon, Islip, Brookhaven, Smithtown, Riverhead, Southampton, East Hampton), Nassau County (Hempstead, Garden City, Mineola, Great Neck, Manhasset, Freeport, Long Beach, Rockville Centre, Valley Stream, Westbury, Hicksville, Massapequa), Suffolk County (Hauppauge, Deer Park, Bay Shore, Central Islip, Patchogue, Brentwood), Queens, Brooklyn, Manhattan, the Bronx, Staten Island, and Westchester County. Prior results do not guarantee a similar outcome.
