The Massachusetts Appeals Court has ruled that a standard automobile insurance policy can limit medical payments coverage when those expenses are already covered by health insurance. This decision affects individuals who may seek to claim medical expenses after an accident, specifically those who have health insurance that covers such costs. The ruling clarifies the interpretation of the medical payments (MedPay) coverage in Massachusetts and reinforces the authority of the state's insurance commissioner.
The case, Bosquet v. Commerce Insurance Company, was filed on September 4, 2026, under docket number AC 25-P-1008. The court's decision is significant because it outlines the boundaries of insurance coverage and the relationship between health insurance and automobile insurance policies in Massachusetts.
The parties involved in this case are Noellen Bousquet, the plaintiff, and Commerce Insurance Company, the defendant. Bousquet was injured in a car accident in July 2018 and incurred over $16,000 in medical expenses. After her health insurer, Fallon Community Health Plan, covered her medical costs, Bousquet sought additional medical payments from her automobile insurer, Commerce. The dispute arose when Commerce denied her claim based on the policy language that prohibits duplicative payments for the same medical expenses already covered by health insurance.
The case began in the Worcester District Court, where a judge ruled in favor of Commerce. Bousquet then appealed to the Appellate Division, which affirmed the lower court's decision. The Appeals Court was tasked with determining whether the language in the 2016 standard Massachusetts automobile insurance policy, which restricts MedPay benefits, conflicts with state law.
The court ruled that the policy language approved by the Commissioner of Insurance does not conflict with Massachusetts law. Judge Neyman stated, "We see no conflict between the 2016 policy language and the statutory language where Massachusetts law allows for reasonable limitations on MedPay benefits under G. L. c. 175, § 113C." The ruling emphasized that the language in the 2016 policy, which prevents duplicate payments, was within the commissioner's authority to approve.
The Appeals Court's decision also referenced a previous case, Golchin v. Liberty Mutual Insurance Company, which established that insurers could limit MedPay benefits under certain conditions. The court noted that the 2016 policy revisions were made to clarify the nonduplication provision, which was absent in earlier versions of the policy.
This ruling has significant implications for Massachusetts drivers. It reinforces the idea that MedPay benefits are secondary to health insurance coverage, meaning that if an individual has health insurance that pays for medical expenses resulting from an accident, they cannot claim those same expenses under their automobile insurance policy. This decision could influence how individuals assess their need for MedPay coverage, especially if they already have health insurance.
The court's ruling does not eliminate MedPay benefits altogether; it simply restricts them in cases where health insurance has already compensated for the medical expenses. This limitation aligns with the public policy of Massachusetts, which allows for reasonable restrictions on insurance coverage.
Looking ahead, Bousquet may have limited options for further appeal. The ruling from the Appeals Court is substantial, and while she could potentially seek further review, the court's affirmation of the lower court's decision indicates a strong judicial stance on the issue. There are no related cases pending that could alter the outcome of this ruling.
In conclusion, the Massachusetts Appeals Court's decision in Bosquet v. Commerce Insurance Company clarifies the relationship between health insurance and automobile insurance in the state. It establishes that MedPay benefits can be limited when expenses are covered by health insurance, impacting how drivers approach their insurance coverage choices in the future.