April 4, 2019
On March 26, 2019, the New Jersey Supreme Court decided the case of Haines v. Taft. The Court had certified the following question: “Does N.J.S.A. 39:6A-12 preclude a plaintiff from recovering medical expenses above those collectible or paid under an insured’s PIP provision in a standard automobile insurance policy, including medical expenses exceeding any elected PIP option allowed pursuant to N.J.S.A. 39:6A-4.3(d)?” When the Court finally rendered its opinion, however, its decision did not cover the expanse of the certified question. Instead, Justice LaVecchia, held together a three justice majority by answering a narrower issue. Specifically, the Haines opinion did not concern all medical bills in excess of the plaintiff’s PIP option. Rather, Haines addressed only “stand alone” suits exclusively…