Court of Appeals overturns judge's decision; reinstates jury verdict that State Farm owed no PIP benefits

Samantha Norris-Jury sued her insurer, State Farm, to compel it to pay certain no fault personal injury protection (PIP) benefits after a car accident.  State Farm paid certain expenses, but argued that the car accident was not a "significant contributing factor" in her knee injury and surgery.  The jury rejected her claim, but the trial judge attributed the jury verdict to confusion in the jury instructions and apparently deemed it "against the great weight of the evidence," given the instructions provided to the jury.

The judge entered his own judgment, awarding Norris-Jury the cost of certain "admitted" PIP expenses and partial attorneys fees.  State Farm appealed.

The higher court ruled that the judge's decision was wrong, both procedurally and substantively.  It concluded that the accident victim's attorneys did not prove fraud that would have justified failing to seek relief from the jury verdict within one year, and that the lower court judge's actual decision was an abuse of discretion because there was some evidence to support the verdict, and her attorneys had contributed to the confusing components of the jury instructions.

Even though the insurance attorney had stipulated that certain prescription expenses would and should be paid, the jury had been instructed to consider only the woman's knee injury and it returned a verdict holding that she suffered no injury in the accident.  Since Norris-Jury's attorneys contributed to the confusion about how the jury was instructed, the Court held she was not entitled to relief from this confusion.  The Court also held that simply because the insurer had chosen not to dispute certain PIP claims, this did not constitute a formal admission of responsibility for those claims. 

The higher court did note that just as the injured woman was not entitled to entry of a judgment holding State Farm responsible for expenses outside the litigated knee claim, similarly, State Farm was not entitled to a holding that was broader than the actual verdict relating to the knee injury.