Key Takeaway
Appellate Division clarifies that self-insured defendants face six-year statute of limitations for no-fault claims, treating them as contractual rather than statutory matters.
The statute of limitations for no-fault insurance claims can vary significantly depending on the type of defendant involved. A recent Appellate Division decision has provided important clarity on this issue, particularly regarding claims against self-insured entities like the New York City Transit Authority.
This case addresses a fundamental question in no-fault insurance law: whether claims against self-insured defendants should be subject to the three-year statutory limitation period that typically applies to insurance claims, or the longer six-year contractual limitation period. The distinction matters enormously for injured parties and their healthcare providers seeking to recover benefits, as it can determine whether a claim filed years after treatment is still viable.
The Appellate Division’s ruling reinforces the principle that self-insured entities occupy a unique position in no-fault litigation. Unlike traditional insurance companies that are bound by specific statutory frameworks, self-insured defendants are viewed through a contractual lens, which extends the time period for bringing claims. This interpretation has significant practical implications for practitioners handling no-fault cases involving self-insured defendants.
Jason Tenenbaum’s Analysis:
Contact Chiropractic, P.C. v New York City Tr. Auth., 2016 NY Slip Op 00325 (2d Dept. 2016)
“The Appellate Term correctly determined that an action by an injured claimant, or his or her assignee, to recover first-party no-fault benefits from a defendant who is self-insured, is subject to a six-year statute of limitations, since the claim is essentially contractual, as opposed to statutory, in nature”
Congratulations to my friend Aaron J. Perretta on his victory here. Given the brevity of the opinion, I am at a loss to understand why leave was granted to Appellant to hear this case,
Key Takeaway
This decision solidifies the six-year contractual statute of limitations for claims against self-insured defendants in no-fault cases. For healthcare providers and injured parties, this ruling provides additional time to pursue valid claims that might otherwise be time-barred under the shorter three-year statutory period. Understanding when different limitation periods apply is crucial for maximizing recovery opportunities in no-fault litigation.
