Key Takeaway
Court ruling demonstrates the challenging burden healthcare providers face when establishing prima facie cases in no-fault insurance summary judgment motions.
Understanding Prima Facie Requirements in No-Fault Insurance Cases
The concept of establishing a “prima facie” case represents one of the most significant hurdles healthcare providers face when pursuing no-fault insurance claims through summary judgment motions. This legal standard requires plaintiffs to demonstrate, as a matter of law, that they are entitled to judgment without the need for a trial. In the context of no-fault insurance disputes, this typically means proving that an insurance company’s denial was either untimely or lacked merit.
The recent Appellate Term decision in A.B. Med., PLLC v GEICO illustrates just how demanding this standard can be for medical providers seeking payment for services rendered to patients injured in motor vehicle accidents. The case demonstrates that even when pursuing what might seem like straightforward claims, the burden of establishing a prima facie case remains substantial and technically demanding.
Understanding these requirements is crucial for healthcare providers navigating the no-fault system, as failure to meet the prima facie standard at the summary judgment stage can result in costly and time-consuming litigation.
Jason Tenenbaum’s Analysis:
A.B. Med., PLLC v GEICO, 2013 NY Slip Op 50203(U)(App. Term 2d Dept. 2013)
“As plaintiff’s affidavit in support of its motion failed to demonstrate that defendant’s denial of claim forms were either untimely or without merit as a matter of law, plaintiff failed to establish its prima facie [*2]entitlement to summary judgment.”
These prima facie cases are extremely tough on the plaintiff’s bar. I wonder if this formulation will find its way to the trial context?
Key Takeaway
This decision reinforces the stringent evidentiary requirements healthcare providers must meet when seeking summary judgment in no-fault cases. The court’s emphasis on demonstrating that denials are “without merit as a matter of law” sets a high bar that often requires careful analysis of the denial document itself and comprehensive supporting documentation. Providers should ensure their affidavits thoroughly address both the timeliness and substantive merit of insurance company denials before pursuing summary judgment.
