Why Trust This Analysis
This article is part of our ongoing causation coverage, with 178 published articles analyzing causation 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.
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:
Free Consultation · No Fee Unless We Win
Does this apply to your situation?
Every case is different. Get a free, confidential case review from an experienced attorney who can tell you exactly where you stand.
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.
Related Articles
Legal Context
Why This Matters for Your Case
New York law is among the most complex and nuanced in the country, with distinct procedural rules, substantive doctrines, and court systems that differ significantly from other jurisdictions. The Civil Practice Law and Rules (CPLR) governs every stage of civil litigation, from service of process through trial and appeal. The Appellate Division, Appellate Term, and Court of Appeals create a rich and ever-evolving body of case law that practitioners must follow.
Attorney Jason Tenenbaum has practiced across these areas for over 24 years, writing more than 1,000 appellate briefs and publishing over 2,353 legal articles that attorneys and clients rely on for guidance. The analysis in this article reflects real courtroom experience — from motion practice in Civil Court and Supreme Court to oral arguments before the Appellate Division — and a deep understanding of how New York courts actually apply the law in practice.
About This Topic
Causation in New York Personal Injury & No-Fault Law
Causation — proving that the defendant's negligence or the accident caused the plaintiff's injuries — is an essential element of every personal injury and no-fault claim. New York courts distinguish between proximate cause, intervening causes, and pre-existing conditions that may have been aggravated by an accident. The legal standards for establishing causation through medical evidence and the defenses available to challenge causal connection are analyzed in depth across these articles.
178 published articles in Causation
Keep Reading
More Causation Analysis
IME no-show is a policy defense triggering the hourly attorney fee provision
Learn how IME no-show defenses trigger hourly attorney fee provisions in NY no-fault insurance. Court rules failure to attend IME is policy defense.
May 22, 2021
Contractual deemer
New York courts examine when out-of-state insurers can avoid no-fault coverage obligations through contractual deemer provisions and policy language analysis.
Apr 24, 2021
Proof that the injury was pre-existing was not refuted
Russell v Cornell University: unchanged prior neck findings, an unsupported aggravation opinion, and the causation proof needed on the motion.
Oct 20, 2013
The Appellate Division grants an Article 75 petition and remands the matter back to AAA arbitration
Appellate Division grants Article 75 petition in MVAIC v Interboro Medical, remanding no-fault arbitration case back to AAA for coverage determination.
May 31, 2010
Another arbitration only rule bites the dust
Global Liberty v Medco Tech: Jason’s 2019 appeal on post-surgical equipment causation, the peer-review record and why the court ordered a new hearing.
Mar 23, 2019
Staged accident not proven
Court rules insurance company failed to prove staged accident claims due to inadmissible evidence and lack of personal knowledge in NY no-fault case.
May 10, 2016Was this article helpful?
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 causation 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.
