Country-Wide Ins. Co. v. Kolb Radiology, P.C.

2024 NY Slip Op 32587(U)
CourtNew York Supreme Court, New York County
DecidedJuly 23, 2024
DocketIndex No. 653038/2020
StatusUnpublished

This text of 2024 NY Slip Op 32587(U) (Country-Wide Ins. Co. v. Kolb Radiology, P.C.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Country-Wide Ins. Co. v. Kolb Radiology, P.C., 2024 NY Slip Op 32587(U) (N.Y. Super. Ct. 2024).

Opinion

Country-Wide Ins. Co. v Kolb Radiology, P.C. 2024 NY Slip Op 32587(U) July 23, 2024 Supreme Court, New York County Docket Number: Index No. 653038/2020 Judge: Anar Rathod Patel Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 653038/2020 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 07/23/2024

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: PART 45 ---------------------------------------------------------------------X COUNTRY-WIDE INSURANCE COMPANY INDEX NO. 653038/2020

Petitioner, MOTION DATE 07/10/2020 -v- KOLB RADIOLOGY, P.C., MOTION SEQ. NO. 001 Respondent. DECISION + ORDER ON MOTION ---------------------------------------------------------------------X HON. ANAR RATHOD PATEL:

The following e-filed documents, listed by NYSCEF document number (Motion 001) 1–7, 9–19, 21 were read on this motion to/for VACATE – DECISION / ORDER / JUDGMENT / AWARD.

Relevant Factual and Procedural History

This is a special proceeding, pursuant to CPLR Article 75, commenced by Petitioner Country- Wide Insurance Company (“Country-Wide” or “Petitioner”) seeking an order and judgment vacating a no-fault master arbitration award of Steven Rickman (dated January 5, 2020), which affirmed the arbitration award of Tara Maher (dated September 15, 2019) granting Respondent Kolb Radiology’s (“Kolb” or “Respodent”) claim for no-fault insurance compensation for health service expenses. Arbitrator Maher awarded the amount of $1,790.67, together with interest, attorney’s fees, and additional fees, sought by Kolb for providing services to its assignor, who claimed to have been injured in a motor vehicle collision on July 27, 2017.

Country-Wide commenced the present action by filing a Notice of Petition and Petition on July 10, 2020. NYSCEF Doc. Nos. 1, 2. This matter was originally assigned to Judge Debra James and was reassigned subsequently to this Court.

Discussion

The standard of review in Article 75 proceedings depends on the amount awarded by the arbitrator. Where the amount in contention does not exceed five thousand dollars ($5,000.00), courts grant deference to the findings of the arbitrators. “In cases of compulsory arbitration, this court has held that CPLR article 75 ‘includes review . . . of whether the award is supported by evidence or other basis in reason.’ This standard has been interpreted to import into article 75 review of compulsory arbitrations the arbitrary and capricious standard of article 78 review.” Matter of Petrofsky (Allstate Ins. Co.), 54 N.Y.2d 207, 211 (1981) (quoting Mount St. Mary’s Hosp. of Niagara Falls v. 653038/2020 COUNTRY-WIDE INSURANCE COMPANY vs. KOLB RADIOLOGY, P.C. Page 1 of 4 Motion No. 001

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Catherwood, 26 N.Y.2d 493, 508 (1970)). Thus, if the amount awarded in arbitration is less than the statutory amount, the judiciary is restricted by the findings of the arbitrators. Only when review has basis in an enumerated ground in CPLR § 7511, or the court finds that the arbitration award is a result of arbitrary or capricious determinations by the arbitrators, may the court interject.

“Further, ‘a court is bound by the arbitrator’s factual findings and interpretations of the contract,’ and it ‘cannot examine the merits of an arbitration award and substitute its judgment for that of the arbitrator simply because it believes its interpretation would be the better one.’ The ‘arbitrator’s award will not be vacated for errors of law and fact committed by the arbitrator and the courts should not assume the role of overseers to mold the award to conform to their sense of justice.’” Metro. Transp. Auth. v. Westfield Fulton Ctr., LLC, No. 2023–03965, 2024 WL 2853484, at *1 (1st Dept. 2024) (internal citations omitted).

As the amount at issue, $1,790.67, is less than the statutory amount, this Court will review the arbitrator’s award under an arbitrary and capricious standard. This Court will only vacate the award if it was granted as a result of arbitrary and capricious determinations by the arbitrators or if there is basis in an enumerated ground in CPLR § 7511(b). “[J]udicial review of arbitration awards is extremely limited. An arbitration award must be upheld when the arbitrator ‘offer[s] even a barely colorable justification for the outcome reached.’” Wien & Malkin LLP v. Helmsley-Spear, Inc., 6 N.Y.3d 471, 479 (2006).

A party seeking to vacate or modify an arbitrator’s award must bring an Article 75 proceeding within 90 days of the delivery of the award. CPLR § 7511(a). Country-Wide initiated this action on July 10, 2020, which is well past 90 days of receiving the arbitrator’s award. However, Petitioner contends that this delay was due to former Governor Cuomo’s COVID-19 Executive Order which temporarily halted filings within the court system beginning on March 20, 2022. The courts have previously determined that Governor Cuomo’s order acted as a toll, extending the statutory time to file proceedings by, approximately, 228 days. See Murphy v. Harris, 177 N.Y.S.3d 559 (1st Dept. 2022); Brash v. Richards, 149 N.Y.S.3d 560 (2d Dept. 2021). Accordingly, Petitioner is entitled to an extension, thereby rendering the present matter as timely.

Country-Wide contends that an arbitrator granting an award while there remained outstanding verification requests amounts to the arbitrator “exceeded his authority or so imperfectly executed it that a final and definite award upon the subject matter was not made.” CPLR § 7511(b)(1)(iii). The hearing arbitrator made the factual determination that Country-Wide did request verification, and Respondent responded to such requests by requesting five dollars ($5.00) as Respondent is entitled to. The hearing arbitrator determined:

The claim was not denied but delayed for verification. At the hearing of this matter, the parties summarized the verification requests in issue and the supports for the same contained in the records.

The evidence establishes that the bill for date of service 3/6/18 was received on 3/22/18 and respondent pended the claim seeking items of additional verification consisting of the MRI films/CD, referral for MRI and MRI safety questionnaire by way of verification requests on 4/12/18 and 5/13/18. The evidentiary record establishes that on 5/7/18 and 5/25/18 applicant provided 653038/2020 COUNTRY-WIDE INSURANCE COMPANY vs. KOLB RADIOLOGY, P.C. Page 2 of 4 Motion No. 001

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the MRI referral and safety questionnaire and requested that [p]ursuant to Radiology Ground Rule 8, a copy of the MRI film/CD electronic [m]edia will be provided upon receipt of $5.00. Thereafter, on 6/6/18 respondent issued a response acknowledging receipt of the response and advising that the MRI films/CD remain outstanding. Bill for date of service 3/21/18 was received on 4/11/18, the first verification was issued on 5/13/18 with a follow up verification issued on 6/6/18 seeking the identical items. The record contains a response to the verification of 6/6/18 wherein applicants provided the MRI referral and safety questionnaire and requested that [p]ursuant to Radiology Ground Rule 8, a copy of the MRI film/CD electronic [m]edia will be provided upon receipt of $5.00.

....

In this instance, Respondent made a proper request for verification but applicant made a proper response in requesting a fee of $5.00 for the MRI film. Having failed to provide the fee required by the Fee Schedule, respondent fails to demonstrate that it has satisfactorily delayed the claim.

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Related

Wien & Malkin LLP v. Helmsley-Spear, Inc.
846 N.E.2d 1201 (New York Court of Appeals, 2006)
Brash v. Richards
2021 NY Slip Op 03436 (Appellate Division of the Supreme Court of New York, 2021)
Mount St. Mary's Hospital v. Catherwood
260 N.E.2d 508 (New York Court of Appeals, 1970)
In re the Arbitration between Petrofsky & Allstate Insurance
429 N.E.2d 755 (New York Court of Appeals, 1981)
Blumenkopf v. Rose
95 A.D.3d 647 (Appellate Division of the Supreme Court of New York, 2012)
Allstate Insurance v. Keegan
201 A.D.2d 724 (Appellate Division of the Supreme Court of New York, 1994)

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Bluebook (online)
2024 NY Slip Op 32587(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/country-wide-ins-co-v-kolb-radiology-pc-nysupctnewyork-2024.