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National Law Review
National Law Review
7/15/2026
The original headline is: "NJ Supreme Court: Future Medical Expenses Within PIP Limits Are Inadmissible"

The original headline is: "NJ Supreme Court: Future Medical Expenses Within PIP Limits Are Inadmissible"

Original: NJ Supreme Court: Future Medical Expenses Within PIP Limits Are Inadmissible

Short summary

The NJ Supreme Court in Murray v. Punina unanimously held that future medical expenses within a claimant's PIP coverage limits are inadmissible at trial against a tortfeasor, applying equally to standard auto policies and UCJF claimants. The Court reasoned that PIP creates an automatic legal entitlement to payment up to policy limits, making future expenses 'collectible' even if treatment hasn't occurred yet. This prevents double recovery and preserves the cost-control logic of New Jersey's no-fault system.

  • Future medical expenses within PIP limits are inadmissible at trial under N.J.S.A. 39:6A-12
  • Ruling applies to both standard auto policy and UCJF claimants equally
  • Court distinguishes 'unpaid' from 'not collectible'—PIP entitlement is automatic upon expense incurrence

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