A New York court has ruled in favor of State Farm Insurance Company, dismissing a claim by 360 Wellness PT PLLC for medical reimbursement. The decision, made on November 6, 2026, affects the medical provider and its assignor, Lidio Hinojosa, who failed to appear for required examinations under oath (EUOs). This ruling underscores the importance of compliance with insurance procedures in no-fault claims.

The case, indexed as CV-719762-24/BX, began when 360 Wellness, acting as an assignee for Hinojosa, sought reimbursement for medical services rendered following a car accident. The court's decision highlights the legal obligations of claimants in the context of New York's no-fault insurance law.

Background

The parties involved in this case are 360 Wellness PT PLLC, a physical therapy provider, and State Farm Insurance Company, a major auto insurer. The dispute arose after Hinojosa was injured in an automobile accident on February 7, 2024. Following the accident, 360 Wellness provided physical therapy services to Hinojosa, billing State Farm a total of $639.85.

State Farm denied the claims for reimbursement after Hinojosa failed to appear for two scheduled EUOs. The insurer argued that his absence constituted a breach of a condition precedent necessary for coverage. The case reached the Civil Court of the City of New York, Bronx County, where Judge Eric J. Wursthorn presided.

The Ruling

The court ruled in favor of State Farm, granting its motion for summary judgment and denying 360 Wellness's cross-motion for partial summary judgment. Judge Wursthorn stated, "The failure of a person eligible for no-fault benefits to appear for a properly noticed EUO constitutes a breach of a condition precedent vitiating coverage." This ruling emphasized the importance of attending EUOs as part of the claims process.

In the court's opinion, State Farm met its burden of proof by demonstrating that Hinojosa had failed to appear for two properly scheduled EUOs. The judge noted that the insurer had provided sufficient justification for the need for continued EUOs, stating, "The transcript itself constitutes documentary proof of the specific objective justification for the continued EUO."

Impact

This ruling has significant implications for medical providers and their patients in New York's no-fault insurance system. It reinforces the necessity for claimants to comply with insurer requests for examinations under oath. The court's decision clarifies that failure to attend these examinations can lead to the dismissal of claims for reimbursement, even if the medical services were provided.

The outcome of this case may set a precedent for similar disputes in the future, emphasizing the importance of following procedural requirements laid out by insurance companies. It serves as a reminder that compliance with EUO requests is crucial for maintaining eligibility for no-fault benefits.

What's Next

Details were not available in the court filing regarding whether the decision can be appealed. However, given the nature of the ruling, it is possible that 360 Wellness may consider further legal action. There are no related cases pending that were mentioned in the opinion.