In Ramkumar v. Grand Style Transp. Enters. Inc., 22 NY3d 905, (2013), the Court of Appeals considered the denial of further no-fault benefits and the ensuing cessation of treatment, and found that the requirement of additional evidence to support a plaintiff's statement was an unwarranted expansion of the landmark case, Pommells v. Perez. The court noted that while it would have been preferable for the plaintiff to submit an affidavit in opposition to summary judgment explaining why the no-fault insurer terminated his benefits and that he did not have medical insurance to pay for further treatment, the plaintiff satisfied the bare minimum required to raise an issue of fact regarding "some reasonable explanation" for the cessation of physical therapy. However, in addition to the explanation for the cessation of treatment, the Ramkumar plaintiff's medical evidence indicated that the arthroscopic surgery, which was performed on the plaintiff's knee for a meniscal tear injury, was determined to be causally related to the car accident.