Key Takeaway
Court ruling demonstrates how contemporaneous medical records can establish causation between accidents and injuries, with implications for no-fault insurance claims.
Establishing Causation Through Medical Records: A Key Court Ruling
Proving causation between an accident and resulting injuries is fundamental to both personal injury litigation and no-fault insurance claims. One of the most compelling forms of evidence attorneys can present is contemporaneous medical records — documentation of treatment that begins immediately or soon after an incident occurs.
The timing of medical treatment often speaks volumes about the connection between an accident and claimed injuries. When a patient seeks medical care within days of an incident, it creates a strong inference that the treatment is related to that specific event. This principle becomes particularly important in cases where insurance companies attempt to deny coverage by arguing that injuries were pre-existing or unrelated to the covered incident.
Medical records that document the onset of symptoms, initial complaints, and treatment protocols provide objective evidence that can withstand scrutiny from defense attorneys and insurance adjusters. Unlike subjective testimony about pain or discomfort, these records represent real-time documentation by healthcare professionals of a patient’s condition following an accident.
Jason Tenenbaum’s Analysis:
Sanchez v Draper, 2014 NY Slip Op 08584 (1st Dept,. 2014)
“Plaintiff also submitted certified medical records of the physical therapy and chiropractic treatment he started receiving within days of the accident. Such evidence supports a finding of a causal connection between the accident and the injuries”
In light of Amato, this has a potential application in first-party practice.
Key Takeaway
The Sanchez decision reinforces that prompt medical treatment following an accident can serve as powerful evidence of causation. For practitioners handling no-fault insurance matters, this principle can be particularly valuable when insurance carriers challenge the relationship between claimed injuries and covered incidents. The contemporaneous nature of medical records can help break the chain of causation arguments often raised by insurers.
Legal Update (February 2026): Since this 2014 post, New York’s no-fault regulations and medical documentation requirements may have been amended, particularly regarding contemporaneous record standards and causation proof requirements. Practitioners should verify current Insurance Law provisions and any updated Department of Financial Services regulations governing medical record sufficiency in no-fault claims.
