Justia New York Court of Appeals Opinion Summaries

Respondent brought this action against appellant to compel payment of no-fault benefits in the amount of its bill, plus statutory interest and attorney's fees, alleging that it had provided timely notice and proof of claim under 11 NYCRR 65-1.1, which required an insured person's assignee to submit written proof of claim no later than 45 days after the date health care services were rendered. At issue was whether a health care services provider, as assignee of a person injured in a motor vehicle accident, could recover no-fault benefits by timely submitting the required proof of claim after the 30-day period for providing written notice of the accident had expired. The court held that the submission of the proof of claim within 45 days of the date health care services were rendered could not serve as timely written notice of accident after the 30-day period for providing such written notice had expired. View "New York and Presbyterian Hospital v. Country Wide Ins. Co." on Justia Law

This case stemmed from a dispute over the status of a negotiated settlement agreement pertaining to New York City's duty to provide mental health services to certain inmates in its jails. At issue was whether the terms of the agreement expired before plaintiffs filed a motion in Supreme Court seeking to extend the City's obligations. Applying the state's traditional principles of contract interpretation, the court held that plaintiffs sought relief prior to termination of the settlement agreement and their motion was therefore timely filed. View "Brad H., et al. v. The City of New York, et al." on Justia Law

Respondent, a designee of the New York City Department of Health and Mental Hygiene, petitioned for an order under Mental Health Hygiene Law 9.60 requiring assisted outpatient treatment ("AOT") for Miguel M. At issue was whether the Privacy Rule adopted by the federal government pursuant to the Health Insurance Portability and Accountability Act ("HIPAA"), 42 U.S.C. 1320d-2, prohibited respondent from disclosing, at the petition hearing, records from two hospitals related to three occasions on which Miguel was hospitalized. The court held that the Privacy Rule prohibited the disclosure of a patient's medical records to a state agency that requested them for use in a proceeding to compel the patient to accept mental health treatment where the patient had neither authorized the disclosure nor received notice of the agency's request for the records. Accordingly, the medical records at issue were not admissible in a proceeding to compel AOT.