Double Recovery of PIP Medical Benefits Blocked by NJ High Court Decision
New Jersey Supreme Court Clarifies When Future Medical Expenses Can Be Claimed Following a Car Collision
TRENTON, NEW JERSEY (May 14, 2026) – New Jersey has a no-fault insurance system that is designed to help make sure that all victims of car accidents are able to quickly access medical benefits.
The same system also prevents accident victims from recovering damages for the same medical bills twice. A recent New Jersey Supreme Court decision has reinforced that long-standing rule.
In Murray v. Punina, the state’s highest court held that car accident plaintiffs are not able to present future medical expenses to a jury if those expenses are still available through PIP benefits.
The decision is important because future medical care is typically a very large part of any personal injury claim. Surgeries and additional therapies can greatly impact the cost of treatment.
Under this ruling, a plaintiff’s ability to collect future medical expenses against an at-fault driver will depend on whether or not they still have access to PIP benefits.
Future Medical Expenses Within PIP Limits Cannot Be Damages Awarded by a Jury
The New Jersey Supreme Court has made it clear that when a person has medical care that can still be legally paid through PIP, that injured person is not able to recover those damages against the person determined to be at fault. The court distinguished between bills that are “collectible or paid.” Any medical expenses that have not already been paid can be considered “collectible.” Future medical bills may still be collectible if they are still eligible for payment under PIP at the time the treatment is received. What follows are a few key points from the decision.
- PIP Covered Expenses: PIP-covered medical expenses are generally excluded from trial when they are still payable through PIP.
- Future Medical Expenses: Future medical expenses can still be considered collectible. However, the fact that a treatment has not happened does not necessarily mean that expense can be recoverable in a personal injury lawsuit.
- UCJF Benefits: The decision from the court also applies to UCJ health benefits as well.
- Double Recovery: The court has made it clear that the goal of the decision is to prevent double recovery. In particular, the court did not want plaintiffs to recover the same category of medical expenses. PIP and an at-fault driver.
To be clear, future medical expenses can be covered by a jury award–so long as those medical expenses are not also covered by PIP. One of the major consequences of the court’s decision is that it significantly affects the value of cases prior to a trial. It is well known that future medical bills tend to play a large role in the total value of a case and thus settlement discussions. This makes it very important for personal injury attorneys to carefully evaluate how much PIP coverage is available and how much has already been used.
Getting Legal Help After a New Jersey Car Accident
We at Beninato & Matrafajlo extend our best wishes to all of the individuals and families who have been affected by car accidents across New Jersey. This decision by the New Jersey Supreme Court reaffirms the importance of seeking skilled legal representation after any collision. An attorney familiar with this ruling can help carefully separate what damages can be recovered in a legal claim and what may be pursued through PIP.
Have you or someone that you care about been injured in a New Jersey car accident? You may have legal recourse. Our team of New Jersey auto accident lawyers is here for you. We are committed to helping victims get all of the medical and financial support that they are entitled to under the law. Whether you just have legal questions or need a free, independent investigation into the unique facts of any case, we are here for you. You can reach out to us anytime at 908-248-4404.
Dan T. Matrafajlo, Esq. is the Managing Member and Lead Partner at Beninato & Matrafajlo, Attorneys at Law, LLC, a New Jersey-based personal injury law firm with offices in Elizabeth and East Brunswick. With over two decades of experience representing clients in complex matters—including motor vehicle accidents, workers’ compensation, and wrongful death cases—he has recovered over $100 million on behalf of his clients and is known for securing significant results. He has also helped shape New Jersey personal injury law through notable Appellate Division decisions such as Hardison v. King and Frenklakh v. Lojek, with his litigation work featured in the New Jersey Law Journal, underscoring his authority in the field.
Mr. Matrafajlo was recognized as a Super Lawyers® Rising Stars honoree from 2012 to 2017 and is a member of the Million Dollar Advocates Forum—an honor reserved for attorneys who have achieved multi-million-dollar verdicts and settlements. Combining deep legal expertise with a client-focused approach, he provides strategic, results-driven representation while guiding clients through every stage of the legal process. He earned his Juris Doctor from the University of Miami School of Law and is admitted to practice in both New Jersey and New York.
