Sunrise Medical Imaging, P.C. v. Liberty Mutual Ins. Co

In Sunrise Medical Imaging, P.C. v. Liberty Mutual Ins. Co., 2001 NY Slip Op 40091U (Dist Ct Nassau Co), Plaintiff sued as assignee for first-party benefits, seeking payment for two MRI's conducted on the insured / assignor that the insurer contended were not "medically necessary." The court concluded that, regardless of which party had the burden of proof on the issue, "the record here establishes that the 'MRI's' served a valid medical purpose." (Id. at 4.) The court rejected the "defendant's claim that the actual medical benefit that the test proved to have is irrelevant when determining whether the test is 'medically necessary' [as] an assertion that defies common sense." (Id. at 4-5.)