State Farm clobbered for repeatedly disputing PIP benefits
Antonina Juzba suffered a severe brain injury in a motor vehicle accident. She was insured for no fault benefits by State Farm. The insurer paid for her treatment initially, but stopped paying after she spent months at the Rainbow Rehabilitation Center and the Ann Arbor Rehabilitation Center (AARC).
In 2004, Juzba sued State Farm and secured a jury verdict for PIP benefits in 2006. Within days, State Farm stopped paying again and Juzba was forced to file suit again. Juzba's attorneys relied on concessions made by State Farm regarding the reasonableness of certain charges, and the Affidavit of AARC's licensed psychologist/director, to seek summary disposition based on collateral estoppel: that is, Juzba claimed that nothing had changed in the days following the jury's decision that benefits were necessary, reasonable, and owed.
State Farm claimed that it could dispute the current obligation based on the bare argument that no one requires head injury treatment "ad infinitum". The Court noted that State Farm offered no documentation to support its claim that Juzba's condition or needs had changed, and granted Juzba summary disposition, awarding fees and costs as well as the cost of services.