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No-Fault Insurance Law

Mallela & Fraudulent Incorporation

Case notes on the Mallela defense: provider licensing and ownership, fraudulent incorporation, and the discovery fights that come with it.

24 articles from 2009–2021 · 0 current · 0 reviewed case notes · by Jason Tenenbaum

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Older archive

Case notes as they were written at the time. They have not been re-checked against later decisions, so treat them as history and confirm the current rule before relying on one.

2021 (1)
2018 (1)
2017 (3)
2016 (2)
2015 (3)
2014 (1)
2013 (2)
2012 (2)
2011 (2)
2010 (5)
2009 (2)

Frequently asked questions

What are Mallela issues in no-fault insurance?

"Mallela issues" concern whether a provider is eligible for reimbursement at all because of who owns or controls it. A provider that fails any applicable New York licensing requirement is not eligible (11 NYCRR 65-3.16(a)(12)). The Court of Appeals held that a medical corporation fraudulently incorporated under Business Corporation Law §§ 1507 and 1508, which require licensed-professional ownership, is not entitled to reimbursement, and that carriers may look beyond the face of licensing documents for willful and material failure to abide by state and local law; technical violations will not do (State Farm Mut. Auto. Ins. Co. v Mallela, 4 NY3d 313 (2005)).

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