Joshua Haines v. Jacob W. Taft: What It Means for New Jersey Motorists

In a landmark case regarding the no-fault traffic laws of the state of New Jersey, Joshua Haines v. Jacob W. Taft was finally decided by the New Jersey Supreme Court on March 26, 2019. The court ruled that plaintiffs in motor vehicle lawsuits cannot seek coverage for medical expenses that occur in the gap between the $15,000 personal injury protection (PIP) coverage required by the state of New Jersey and the maximum of $250,000 available to motorists within the state.

The Initial Complaint

The initial complaint filed by Joshua L. Haines indicated that he was involved in an accident caused by the negligence of Jacob W. Taft. Haines was covered by his father’s automobile insurance, which included PIP coverage of $15,000 with a $2,500 deductible. The medical bills incurred by Haines, however, exceeded this amount by about $28,000. Haines filed to recover the uncompensated medical expenses from Taft. After barring Haines from admitting his medical expenses into evidence in court, his complaint was dismissed and the case was appealed to the Superior Court of New Jersey, Appellate Division.

The Appellate Court Decision

In a decision handed down on June 1, 2017, the Appellate Division of the Superior Court of New Jersey reversed the dismissal of Haines v. Taft and sent the case back to the lower court based on the court’s interpretation of New Jersey Statutes Annotated (NJSA) 39:6A-12, which bars the admission of the amounts paid for medical expense benefits and deductibles under PIP into civil actions for recovery of damages. In simpler terms, the statute tells jury members not to consider the amount of money paid by the auto insurance or health insurance company when making a determination about the amount of damages that should be awarded to the plaintiff should he or she prevail in the case. Since these figures are not admissible, they are also not recoverable by the plaintiff.

The Supreme Court Decision

The New Jersey Supreme Court reversed the decision of the appellate court and held that the no-fault policies and regulations implemented in the state of New Jersey, especially NJSA 39:6A-12, are intended to bar plaintiffs from recovering expenses that exceeded their PIP benefits. Since the actual amount of PIP was $15,000 and the possible amount was $250,000, allowing the plaintiff to sue for additional amounts over their own elected PIP limit of $15,000 would encourage lawsuits by underinsured individuals without any regard to their own decision to accept and to pay less for a reduced level of coverage. According to the Supreme Court decision, this would undermine the intent of the no-fault law and the responsibility of individuals to obtain adequate insurance for their own needs.

At the Di Lauri & Hewitt Law Group, we offer the most accurate and effective solutions for your civil litigation and personal injury defense cases. We will work with you to find the most practical solutions for your situation. Call us today at 973-354-5783 to schedule a consultation with us. We look forward to the opportunity to serve you