In a significant ruling, the Appellate Division of the Supreme Court of the State of New York has reversed a lower court's decision in the case of Alam v. Priority One Ambulance, Inc. This ruling affects Masudul Alam, the plaintiff, who sought damages for personal injuries he claimed to have sustained in a motor vehicle accident involving Priority One Ambulance. The court's decision emphasizes the importance of demonstrating a serious injury under New York law.

The court's ruling came on June 24, 2026, and is documented under docket number 2025-02180. The decision is particularly relevant for personal injury claims in New York, where plaintiffs must meet specific criteria to prove they have sustained a serious injury according to Insurance Law § 5102(d).

The dispute began when Alam filed a lawsuit against Priority One Ambulance and its affiliates, alleging he suffered injuries from an accident involving their vehicle. The case was initially heard in Kings County, where the Supreme Court denied the ambulance company's motion for summary judgment, which sought to dismiss Alam's complaint on the grounds that he did not sustain a serious injury.

Following the denial, the ambulance company appealed the decision to the Appellate Division. The court's ruling highlights the ongoing challenges faced by plaintiffs in personal injury cases, particularly regarding the burden of proof required to establish the severity of their injuries.

Background

Masudul Alam, the respondent in this case, claimed that he was injured in a motor vehicle accident involving Priority One Ambulance, Inc. The accident occurred on January 1, 2019, and Alam sought damages for the injuries he alleged he sustained. The defendants, Priority One Ambulance and its affiliates, filed a motion for summary judgment to dismiss Alam's complaint, arguing that he did not meet the legal definition of a serious injury as outlined in New York's Insurance Law.

The legal definition of a serious injury includes significant limitations on the use of a body part, disfigurement, or a permanent injury. In this case, the defendants contended that Alam failed to provide sufficient evidence to support his claims. They pointed out that there was a significant gap in Alam's medical treatment, which raised questions about the validity of his injury claims.

The lower court initially sided with Alam, denying the ambulance company's motion for summary judgment. This decision prompted the appeal, as the defendants argued that the lower court had erred in its assessment of the evidence presented.

The Ruling

The Appellate Division reviewed the case and ultimately reversed the lower court's decision. The court ruled that Alam did not raise a triable issue of fact regarding his injury. The judges noted, "the plaintiff failed to raise a triable issue of fact in opposition to the defendants' motion, as neither he nor his physicians offered a reasonable explanation for the lengthy gap in his treatment from January 2019 to March 2021." This gap in treatment was critical to the court's decision.

The judges further stated, "the plaintiff failed to provide any evidence to support his contention that he stopped treatment due to the COVID-19 pandemic." This lack of evidence contributed to the court's conclusion that Alam did not meet the necessary legal standard for proving a serious injury.

The ruling was made by a panel of judges, including Betsy Barros, Lara J. Genovesi, Lourdes M. Ventura, and Elena Goldberg Velazquez. Their decision underscores the stringent requirements for plaintiffs in personal injury cases to provide clear and consistent evidence of their injuries and treatment.

Impact

This ruling has significant implications for personal injury claims in New York. It highlights the necessity for plaintiffs to maintain consistent medical treatment and documentation to support their claims. The decision may discourage individuals from pursuing claims if they cannot provide sufficient evidence of their injuries or if there are gaps in their treatment history.

Moreover, the ruling reinforces the importance of the legal standards set forth in Insurance Law § 5102(d). Plaintiffs must be prepared to demonstrate that they have sustained serious injuries to succeed in their claims. This case may set a precedent for future cases where gaps in treatment history are present, potentially making it more challenging for plaintiffs to prove their cases.

What's Next

Details were not available in the court filing regarding whether Alam plans to appeal this ruling. However, the decision stands as a critical reminder for individuals pursuing personal injury claims to ensure they have comprehensive medical documentation and a clear treatment history.