Court holds release excluding "healthcare medical services" discharges State Farm liability for wheelchair lift

Barbara Waiters became embroiled in a lawsuit with State Farm over her entitlement to No Fault Personal Injury Protection benefits (i.e., three years' wages and household services and unlimited medical coverage).  She settled the claim with a complete release of all benefits except "reasonable charges for reasonably necessary heatlhcare medical services."  When she needed to purchase a wheelchair lift for her van, State Farm argued that this was not a "healthcare medical service."    The trial judge summarily denied State Farm's claim, and State Farm appealed.

The Court of Appeals, including Judges Hoekstra, O'Connell and Riordan, reversed the lower court, holding that the release was unambiguous and that a wheelchair lift was not a healthcare medical service.  Even though wheelchairs and suitable transportation arrangements and equipment are routine components of PIP medical expenses paid by no fault carriers under PIP benefits, and even though the trial judge ruled that the Release was not intended to waive these benefits, the appellate judges ruled that they had been unambiguously waived by the language quoted above.