A New Jersey court has dismissed a medical provider's claim for reimbursement for services rendered to an employee injured in New York. The ruling affects Landa Spine Center, which sought payment for medical services provided to a New Jersey resident who was injured while working in New York. This decision highlights the complexities of jurisdiction in workers' compensation cases, particularly when injuries occur across state lines.

The case, Landa Spine Center v. Posillico, was filed under docket number A-1311-25 in the New Jersey Superior Court Appellate Division. The court ruled on November 2, 2026, affirming the lower court's decision to dismiss Landa's application for lack of subject matter jurisdiction. This ruling is significant as it clarifies the boundaries of the New Jersey Workers' Compensation Act and its application to medical providers.

Background

The dispute involves Landa Spine Center, a medical provider located in New Jersey, and Posillico, a construction company that operates primarily in New York. The case centers around an employee named Dominic Valinotti, who was injured while working for Posillico in New York. Valinotti, a resident of Matawan, New Jersey, was injured on September 23, 2016, when a pipe struck his leg while he was installing pipes in the Bronx.

After the injury, Valinotti filed a workers' compensation claim with the New York Workers' Compensation Board. He subsequently received various medical treatments, including spinal fusion surgery performed by Dr. Joshua Landa at Landa Spine Center in New Jersey. Following the surgery, Landa submitted a bill for $203,000 to Posillico's workers' compensation insurer, Starr Indemnity and Liability. However, Starr only reimbursed Landa $4,197.40, prompting Landa to seek additional reimbursement through a Medical Provider Application (MPA) filed with the New Jersey Division of Workers' Compensation in February 2021.

The Ruling

The New Jersey court ruled that it lacked subject matter jurisdiction over Landa's MPA. The judge of compensation found that while Valinotti resided in New Jersey, all of his work for Posillico occurred in New York, where he filed his workers' compensation claim. The court noted, "the only factor suggesting subject matter jurisdiction in New Jersey was Valinotti's residency in New Jersey," and emphasized that residency alone does not confer jurisdiction for extra-territorial workplace injuries.

The court's decision was based on the analysis of six factors established in previous case law, known as the Larson factors, which help determine the applicable jurisdiction for workers' compensation claims. The judge found that most of these factors supported the conclusion that New Jersey did not have jurisdiction over Landa's claim. The ruling stated, "we discern no legal error" in the compensation judge's findings, affirming the dismissal of Landa's application.

Impact

This ruling has significant implications for medical providers and injured workers alike. It clarifies that medical providers in New Jersey cannot automatically seek reimbursement for services rendered to injured workers who were employed and injured in another state. The decision underscores the importance of understanding jurisdictional boundaries in workers' compensation cases, especially in situations where employees work across state lines.

Going forward, medical providers like Landa Spine Center must file their reimbursement claims with the appropriate workers' compensation board in the state where the injury occurred. In this case, Landa was directed to file its MPA with the New York Workers' Compensation Board. This ruling may set a precedent for similar cases, reinforcing the need for medical providers to be aware of jurisdictional issues when treating injured workers from different states.

What's Next

Landa Spine Center can appeal the ruling, but the court has already remanded the case with directions to modify the dismissal order to be without prejudice. This allows Landa to pursue its claim for reimbursement with the New York Board. The outcome of that claim will depend on the specifics of New York's workers' compensation laws and the circumstances surrounding Valinotti's injury.