New Jersey Supreme Court Ruling on PIP Future Medical Costs

The New Jersey Supreme Court's recent ruling has clarified that evidence of future medical costs covered by Personal Injury Protection (PIP) is inadmissible in jury trials. This decision, issued on May 6, 2026, in the case of Lakita D. Murray v. Christopher B. Punina, is a significant development for auto insurers aiming to prevent potential double recoveries for the same injury.

The incident leading to the case occurred in August 2016, involving Lakita Murray, a passenger in a car driven by the uninsured Christopher Punina, in a collision with Anthony Marrone. Lacking personal auto coverage, Murray sought compensation from the New Jersey Property-Liability Insurance Guaranty Association, securing up to $250,000 in medical benefits under the Unsatisfied Claim and Judgment Fund. Importantly, her pre-trial medical expenses remained below this limit.

By 2018, Murray had filed a lawsuit against both drivers, resulting in Punina's default. She extended a $50,000 settlement offer to Marrone, which he declined. The legal question centered on whether Murray's projected future medical costs, estimated between $42,000 and $160,000, could be introduced to the jury despite being within her PIP coverage. Initially, the trial judge allowed this testimony despite prohibitions on presenting PIP-covered medical costs in court.

The jury subsequently awarded Murray $250,000 in non-economic damages and $100,000 for future medical expenses, attributing 80% fault to Punina and 20% to Marrone. Marrone incurred additional financial burdens due to pre-judgment interest and fees from rejecting the settlement, totaling over $120,000.

On appeal, the Appellate Division removed the future medical expenses from the compensation awarded, a decision upheld by the Supreme Court. Justice Fasciale, representing the unanimous court, underscored the inadmissibility of such evidence if expenses fall under PIP provisions. The ruling solidifies that future medical costs within PIP limits are always regarded as collectible, reinforcing the notion that such expenses should not be reclaimed from tortfeasors.

The court further asserted that this ruling applies to claimants under the Unsatisfied Claim and Judgment Fund, ensuring regulatory consistency across various insurance frameworks. Addressing concerns about delayed future treatment surpassing PIP's two-year claim period, the court cited legal precedents allowing extensions for anticipated treatment.

Ultimately, the Supreme Court's ruling strengthens the no-fault insurance system in New Jersey, ensuring that PIP-related medical expenses remain outside jury deliberations, thereby protecting insurers and defendants from redundant claims.