A New Jersey court has ruled that Transportation Network Companies (TNCs), such as Lyft, are required to provide Personal Injury Protection (PIP) coverage benefits to uninsured pedestrians injured by their vehicles. This decision affects how TNCs handle insurance claims and sets a precedent for pedestrian safety in the state.
The ruling came from the New Jersey Superior Court Appellate Division in the case of Lamar Boone v. Unsatisfied Claim and Judgment Fund, under docket number A-2772-24. The court decided on July 24, 2026, affirming a lower court's decision that mandated Liberty Mutual Insurance Company, the insurer for Lyft, to reform its policy to include PIP coverage for pedestrians like Boone, who was struck by a Lyft driver.
Boone, an uninsured pedestrian, was hit by a vehicle driven by Jean E. Zamor while operating as a Lyft driver. After Liberty Mutual denied Boone's claim for medical expenses, he sought coverage from the New Jersey Property-Liability Insurance Guaranty Association (NJPLIGA), which also denied his claim. Boone then filed a complaint seeking PIP benefits from Liberty Mutual and NJPLIGA.
The trial court initially denied Liberty Mutual's motion for summary judgment, which sought to dismiss Boone's claims. Instead, the court granted Boone's and NJPLIGA's cross-motions for summary judgment, compelling Liberty Mutual to provide PIP coverage benefits and reforming the policy to include such coverage. Liberty Mutual appealed the decision, arguing that the TNC Act did not require PIP coverage for pedestrians.
The Appellate Division, led by Judge Bergman, ruled that the TNC Act does not exempt TNCs from providing PIP coverage to uninsured pedestrians. The court stated, "the Legislature extended this protection under N.J.S.A. 17:28-1.3, which states that 'every liability insurance policy issued in this State on a motor vehicle... shall provide [PIP] benefits... to pedestrians who sustain bodily injury in the State caused by the named insured's motor vehicle.'" This ruling emphasizes that all motor vehicles, including those used by TNCs, are required to maintain coverage that provides PIP benefits to pedestrians.
The court's decision clarifies the responsibilities of TNCs regarding insurance coverage for pedestrians. It establishes that uninsured pedestrians injured by TNC vehicles are entitled to immediate medical expense coverage, regardless of fault. This ruling aims to ensure that pedestrians are not left without financial support for medical treatment after accidents involving TNC vehicles.
The ruling also has broader implications for the insurance industry and pedestrian safety in New Jersey. It reinforces the notion that all motor vehicle liability policies must include PIP coverage, thereby enhancing protections for vulnerable road users. This decision could influence future cases involving TNCs and insurance coverage, potentially leading to more comprehensive protections for pedestrians in similar situations.
Looking ahead, Liberty Mutual may consider appealing the decision to the New Jersey Supreme Court. However, the court's ruling currently stands, mandating that TNCs must include PIP coverage for uninsured pedestrians. This case sets a significant precedent for how TNCs operate within New Jersey's legal framework and underscores the importance of pedestrian safety in the evolving landscape of transportation.