Teichman v. Community Hospital of Western Suffolk

In Teichman v. Community Hospital of Western Suffolk (87 NY2d 514 [1996]) the Court reiterated the common rule that insurance contracts must be interpreted in the same manner as ordinary contracts, so that courts are to "give unambiguous terms their plain and ordinary meaning." Id. at 520. In Teichman, the insurance company sought a lien on settlement proceeds in an action involving a beneficiary to the plan therein. The provision stated that "if the insurer pays benefits under this Plan for Covered Medical Expenses incurred on the insured's account, and it is found that ... the insured was repaid for all or some of those expenses by another source, the insurer will have the right to a refund from the insuredemphasis supplied." Id. at 520. In Teichman, the Court found that the policy's language contained "nothing regarding a lien" on any recovery its insured might enjoy. Id. at 520. As such, the Teichman Court found that, in light of the plain language of the policy, there was no contractual lien on the settlement proceeds.