Lakita D. Murray v. Christopher B. Punina

CourtSupreme Court of New Jersey
DecidedMay 6, 2026
DocketA-51-24
StatusPublished

This text of Lakita D. Murray v. Christopher B. Punina (Lakita D. Murray v. Christopher B. Punina) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lakita D. Murray v. Christopher B. Punina, (N.J. 2026).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Lakita D. Murray v. Christopher B. Punina (A-51-24) (090246)

Argued February 2, 2026 -- Decided May 6, 2026

JUSTICE FASCIALE, writing for a unanimous Court.

In this appeal, the Court considers whether evidence of plaintiff Lakita Murray’s future medical expenses is admissible in her personal injury trial even though they would not exceed her personal injury protection (PIP) coverage limits.

In August 2016, plaintiff sustained injuries as a passenger in a car accident. She applied for PIP benefits from the New Jersey Property-Liability Insurance Guaranty Association (NJPLIGA) under the terms of the Unsatisfied Claim and Judgment Fund (UCJF). NJPLIGA approved the application, which entitled plaintiff to medical expense benefits up to $250,000. The cost of the medical treatment plaintiff underwent prior to trial did not exceed the limits of her PIP coverage.

Plaintiff filed a personal injury complaint against both drivers involved in the collision. Plaintiff filed an offer of judgment for $50,000, but defendant Anthony Marrone did not accept. Plaintiff’s medical expert opined that plaintiff’s future medical expenses would be between $42,000 and $160,000. The jury awarded plaintiff $250,000 in non-economic damages and $100,000 in damages for future medical expenses. The judgment against Marrone was for $50,000 and $20,000, respectively, plus pre-judgment interests and costs. Pursuant to the offer of judgment rule, the trial court additionally awarded plaintiff $44,107.58.

The Appellate Division reversed in part, finding that evidence of plaintiff’s future medical expenses was inadmissible because those expenses were “collectible” under N.J.S.A. 39:6A-12. Because it found that the future medical expenses should have been excluded, the appellate court also modified the judgment against Marrone to exclude that part of the damages award and to exclude the additional award under the offer of judgment rule. The Court granted certification. 260 N.J. 313 (2025).

HELD: Future medical expense benefits that do not exceed a claimant’s PIP coverage limits are “collectible” for purposes of N.J.S.A. 39:6A-12 and therefore inadmissible during a plaintiff’s personal injury trial against a tortfeasor.

1 1. N.J.S.A. 39:6A-12, a provision of the New Jersey Automobile Reparation Reform Act, commonly known as the No-Fault Act, is titled “Inadmissibility of evidence of losses collectible under personal injury protection coverage.” The provision refers to three types of PIP coverage: a standard automobile insurance policy, a basic automobile insurance policy, and a special automobile insurance policy. Each provides PIP protection to passengers. The UCJF is intended to provide the kind of protection a liability insurance policy would provide so that individuals who sustain losses inflicted by uninsured drivers are not left remediless. The term “personal injury protection coverage,” as used in the UCJF statute, is a general term that encompasses the PIP benefits provided by standard, basic, and special policies, and the statute plainly states that it applies when “[PIP] benefits under the [No-Fault Act] would be payable.” N.J.S.A. 39:6-86.1. UCJF claimants are entitled to protection equivalent to that provided by a liability insurance policy -- no more, no less. N.J.S.A. 39:6A-12 applies to PIP benefits available from the UCJF. (pp. 9-12)

2. As originally enacted, the No-Fault statutory scheme provided for unlimited medical benefits under no-fault insurance. But, “because of the rapidly escalating cost of those benefits,” the Legislature subsequently “reduce[d] those benefits to a limit of $250,000.” N.J.S.A. 39:6A-1.1(b). The statutory scheme thus “preserve[d] the no-fault system [and] reduc[ed] unnecessary costs which drive premiums higher.” Ibid. To further that objective, N.J.S.A. 39:6A-12 bars the admissibility of evidence of losses collectible under PIP and reflects legislative awareness of the need to prevent double recovery by a plaintiff eligible for PIP benefits. The Court reviews the history of the provision and concludes that, under the plain language of N.J.S.A. 39:6A-12 as it now reads, medical expense benefits are inadmissible in a civil trial as damages against a tortfeasor if they are “collectible or paid.” Conversely, uncompensated medical expenses that are not covered by applicable PIP limits are admissible against a liable party under N.J.S.A. 39:6A-12. Future medical expense benefits that are covered under a PIP policy are “collectible” and thus inadmissible in a civil action under N.J.S.A. 39:6A-12. (pp. 12-19)

3. Here, plaintiff’s estimated future medical expenses will not exhaust her PIP limits and are, thus, “collectible.” Those expenses are inadmissible and should not have been presented to the jury or included in the damages award. Further, because the inadmissible future expenses should not have been included in the award against Marrone, the award should also not have included additional costs and fees pursuant to the offer of judgment rule. (pp. 19-20)

AFFIRMED.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, PIERRE-LOUIS, WAINER APTER, NORIEGA, and HOFFMAN join in JUSTICE FASCIALE’s opinion. 2 SUPREME COURT OF NEW JERSEY A-51 September Term 2024 090246

Lakita D. Murray,

Plaintiff-Appellant,

v.

Christopher B. Punina, Christoph Punina, New Jersey Property Liability Guaranty Association, a/k/a NJPLIGA,

Defendants,

and

Anthony Marrone, II,

Defendant-Respondent.

On certification to the Superior Court, Appellate Division.

Argued Decided February 2, 2026 May 6, 2026

Daniel N. Epstein argued the cause for appellant (Epstein Ostrove, and Hegge & Confusione, attorneys; Daniel N. Epstein and Michael Confusione, on the brief).

Stephen J. Foley, Jr., argued the cause for respondent (Campbell, Foley, Delano & Adams, attorneys; Stephen J. Foley, Jr., on the briefs).

1 Dominic R. DePamphilis argued the cause for amicus curiae New Jersey Association for Justice (D’Arcy Johnson Day, attorneys; Dominic R. DePamphilis and Richard J. Albuquerque, on the brief).

Robert A. Cappuzzo argued the cause for amicus curiae New Jersey Defense Association (Chasan Lamparello Mallon & Cappuzzo, attorneys; Robert A. Cappuzzo, on the brief).

JUSTICE FASCIALE delivered the opinion of the Court.

In this appeal, we determine whether evidence of plaintiff’s future

medical expenses is admissible in her personal injury trial when those

projected expenses would not exceed her personal injury protection (PIP)

coverage limits.

Under N.J.S.A. 39:6A-12, a provision of the New Jersey Automobile

Reparation Reform Act, commonly known as the No-Fault Act, a plaintiff

suing a defendant for personal injuries arising out of an automobile accident

cannot introduce evidence of benefits that are “collectible” under PIP

coverage. We hold that future medical expense benefits that do not exceed a

claimant’s PIP coverage limits are “collectible” and therefore inadmissible

during a plaintiff’s personal injury trial against a tortfeasor.

We affirm the Appellate Division’s judgment.

2 I.

In August 2016, plaintiff Lakita Murray sustained injuries in a car

accident. She was a passenger in defendant Christopher Punina’s car when it

collided with a car driven by defendant Anthony Marrone.

Punina’s car was uninsured, and plaintiff did not reside in a household

where either she or a family member insured a car. Consequently, in

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