Marc Feder Dmd, Pc and Marc Feder v. New Jersey Manufacturers Insurance Company

CourtNew Jersey Superior Court Appellate Division
DecidedApril 21, 2025
DocketA-2538-23
StatusUnpublished

This text of Marc Feder Dmd, Pc and Marc Feder v. New Jersey Manufacturers Insurance Company (Marc Feder Dmd, Pc and Marc Feder v. New Jersey Manufacturers Insurance Company) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Marc Feder Dmd, Pc and Marc Feder v. New Jersey Manufacturers Insurance Company, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2538-23

MARC FEDER DMD, PC and MARC FEDER,

Plaintiffs-Appellants,

v.

NEW JERSEY MANUFACTURERS INSURANCE COMPANY,

Defendant-Respondent. ___________________________

Argued April 7, 2025 – Decided April 21, 2025

Before Judges Sabatino, Jacobs, and Jablonski.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-1485-22.

Jeffrey A. Bronster argued the cause for appellants.

Daniel J. Pomeroy argued the cause for respondent (Pomeroy, Heller & Ley, DiGasbarro & Noonan, LLC, attorneys; Daniel J. Pomeroy and Karen E. Heller, on the brief).

PER CURIAM This declaratory judgment action revolves around whether an insurance

company complied with the statutory procedures for cancelling an automobile

insurance policy. Plaintiff Mark Feder 1 failed to pay his overdue insurance

premium of $378.00 to defendant New Jersey Manufacturers Insurance

Company ("NJM"), so NJM took steps to cancel his policy. The steps are

prescribed in N.J.S.A. 17:29C-10, which has two distinct requirements in

subsections (a) and (b):

No written notice of cancellation or of intention not to renew sent by an insurer to an insured in accordance with the provisions of an automobile insurance policy shall be effective unless

a. (1) it is sent by certified mail or (2) at the time of the mailing of said notice, by regular mail, the insurer has obtained from the Post Office Department a date stamped proof of mailing showing the name and address of the insured, and

b. the insurer has retained a duplicate copy of the mailed notice which is certified to be a true copy.

[Emphasis added.]

After considering the documentation supplied by NJM and plaintiff's

arguments in opposition, the trial court granted NJM summary judgment. Based

1 For simplicity, we will refer to Mark Feder as "plaintiff" in this opinion even though his professional business, Mark Feder DMD, PC, is named as a co- plaintiff. A-2538-23 2 on the face of the documents before it, which were not illuminated by any NJM

testimony at a deposition or a plenary hearing, the court concluded NJM

complied with both subsections (a) and (b) of the statute in cancelling plaintiff's

policy. Plaintiff appeals, contending NJM's submissions were inadequate to

prove its compliance.

For the reasons that follow, we affirm the trial court's ruling in part and

vacate it in part. Specifically, we concur with the court's determination that, as

a matter of the law, the record sufficed to establish NJM's compliance with

subsection (a) of N.J.S.A. 17:29C-10 concerning proof of its mailing to plaintiff.

However, we vacate summary judgment as to subsection (b), which was

construed by our opinion in Celino v. General Accident Insurance, 211 N.J.

Super. 538, 543 (App. Div. 1986) to require the insurer prove that, at the time

of the mailing, it "contemporaneously" certified that it was retaining a "true"

duplicate copy of the cancellation notice.

As we elaborate, infra, the cancellation notice and other documents

supplied in the motion record presently lack sufficient information to establish

who certified those crucial facts under subsection (b) and when they were so

certified. The alleged duplicate of the cancellation notice also contains various

unexplained handwritten notations with several dates, which may bear upon the

A-2538-23 3 analysis.

When viewed in a light most favorable to plaintiff in this summary

judgment posture, the present record lacks sufficient evidence of personal

knowledge of subsection (b) compliance with respect to plaintiff's cancellation

notice. See N.J.R.E. 602 and Rule 1:4-4. Nor, alternatively, does the present

record substantiate conclusively NJM's routine practices concerning its

subsection (b) compliance. See N.J.R.E. 406. In sum, there are genuine issues

of material fact that are not capable of resolution on the existing record.

Given that Celino and other case law insists on insurers' strict compliance

with the requirements of N.J.S.A. 17:29C-10, and because the record here must

be developed more fully and clearly to adjudicate NJM's compliance as to

subsection (b) of that statute, we vacate summary judgment and remand this

matter to the trial court for further proceedings.

I.

To provide context to our discussion, we first provide a brief overview of

the statutory scheme and the public policies that underlie N.J.S.A. 17:29C-10.

The statute has been amended at various times until its present form.

The laws of our state have long required the owners of private passenger

vehicles to maintain coverage from an automobile insurance company. N.J.S.A.

A-2538-23 4 39:6A-3. As a matter of public policy, such coverage is important for the

protection of drivers and their passengers who use our roadways, as well as for

pedestrians and the occupants of other vehicles who may be injured by the

insured driver's conduct. See, e.g., Rutgers Cas. Ins. Co. v. LaCroix, 194 N.J.

515, 523-24 (2008).

Given those public policy concerns, the Legislature and our case law have

imposed strict requirements upon automobile insurers to provide reasonable

notice to vehicle owners before cancelling their coverage for non-payment. The

cancellation of coverage can have severe consequences. Our laws therefore

strive to assure that motorists are provided with fair warning that their policies

are about to be cancelled, and a grace period to make delinquent payments in

order to maintain coverage. See N.J.S.A. 17:29C-8. At the same time, the

Legislature and our courts have recognized that the procedures for auto insurers

to cancel coverage should not be unduly burdensome.

Before it was amended in 1980, the cancellation statute provided that,

"[p]roof of mailing of notice of cancellation to the named insured at the address

shown in the policy, shall be sufficient proof of notice." N.J.S.A. 17:29C-10

(amended 1980). In Weathers v. Hartford Ins. Grp., 77 N.J. 228 (1978), the

Supreme Court construed that language to signify that "cancellation may be

A-2538-23 5 effective whether or not the insured has actually received the notice of

cancellation since proof of mailing, not proof of receipt, is the determinative

factor." Id. at 234. Nonetheless, the Court concluded the insurer's proof of its

mailing of the cancellation notice to the insured in that case, while "sufficient to

go to the fact-finder on the issue . . . did not compel a finding of mailing as a

matter of law." Id. at 235. Among other things, the Court noted that the insurer's

witness "conceded it was possible that a given envelope might not contain a

notice to the person purportedly addressed." Ibid.

After the Court's decision in Weathers, the Legislature amended N.J.S.A.

17:29C-10 in 1980 to provide clearer guidelines for appropriately evidencing

"proof of mailing" by requiring at least a date-stamped proof of mailing and—

as is pertinent to our decision on this appeal—a certified copy of the mailed

letter. See S.

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Marc Feder Dmd, Pc and Marc Feder v. New Jersey Manufacturers Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marc-feder-dmd-pc-and-marc-feder-v-new-jersey-manufacturers-insurance-njsuperctappdiv-2025.