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Haines v. Taft

Supreme Court of New Jersey

October 22, 2018, Argued; March 26, 2019, Decided

A-13/14 September Term 2017, 079600

Case Summary

Overview

HOLDINGS: [1]-The court held there was no evidence of a clear intention on the part of the New Jersey Legislature to deviate from the carefully constructed no-fault first-party PIP system of regulated coverage of contained medical expenses and return to fault-based suits consisting solely of economic damages claims for medical expenses in excess of an elected lesser amount of available PIP coverage; [2]-The Court held that unless the Legislature made such an intent clearly known, it would not assume that such a change was intended; [3]-The Court rejected the lower appellate court's interpretation of N.J.S.A. § 39:6A-12 and remanded the matters to the trial courts for entry of judgments of dismissal as § 39:6A-12 prohibited plaintiffs from admitting evidence of their medical expenses that exceeded their $15,000 PIP limits.

Outcome

Judgment of lower appellate court reversed; matters remanded to trial courts for entry of their respective judgments of dismissal.

LexisNexis® Headnotes

 

 

Governments > Legislation > Interpretation

Insurance Law > ... > No Fault Coverage > Personal Injury Protection > Medical Benefits

HN1  Interpretation

The Supreme Court of New Jersey cannot conclude that there is evidence of a clear intention on the part of the New Jersey Legislature to deviate from the carefully constructed no-fault first-party PIP system of regulated coverage of contained medical expenses and return to fault-based suits consisting solely of economic damages claims for medical expenses in excess of an elected lesser amount of available PIP coverage. Unless the Legislature makes such an intent clearly known, the Court will not assume that such a change was intended by the Legislature through its amendments to the no-fault system in the Automobile Insurance Cost Reduction Act (AICRA), L. 1998, c. 21.

 

Insurance Law > ... > No Fault Coverage > Personal Injury Protection > Medical Benefits

HN2  Medical Benefits

In the opening findings and declarations section of Automobile Insurance Cost Reduction Act (AICRA), L. 1998, c. 21, it is the New Jersey Legislature's belief that it is good public policy to provide medical benefits on a first party basis, without regard to fault, to persons injured in automobile accidents, but in order to keep premium costs down, the cost of the benefit must be offset by a reduction in the cost of other coverages, most notably a restriction on the right of persons who have non-permanent or non-serious injuries to sue for pain and suffering. N.J.S.A. § 39:6A-1.1(b) (1998).

 

Governments > Legislation > Interpretation

HN3  Interpretation

A court should not resort to extrinsic interpretative aids when the statutory language is clear and unambiguous, and susceptible to only one interpretation.

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237 N.J. 271 ; 204 A.3d 263 ; 2019 N.J. LEXIS 441 ; 2019 WL 1339479

Joshua Haines, Plaintiff-Respondent, v. Jacob W. Taft, Bonnie L. Taft, jointly, severally and/or in the alternative, Defendants-Appellants, and John McHenry, Defendant.Tuwona Little, Plaintiff-Respondent, v. Jayne Nishimura, Defendant-Appellant.

Prior History: On certification to the Superior Court, Appellate Division, whose opinion is reported at 450 N.J. Super. 295, 162 A.3d 296 (App. Div. 2017) [1] .

Haines v. Taft, 450 N.J. Super. 295, 162 A.3d 296, 2017 N.J. Super. LEXIS 64 (App.Div., June 1, 2017)