Chiropractic Care Centers, Inc. provided medical treatment to Rafael Jimenez after he was injured in a motor vehicle accident.
Chiropractic sought payment of medical bills from Allstate Insurance, the patient's PIP insurer. Allstate asserted that Chiropractic's claims were extinguished when the patient signed a release of his uninsured motorist coverage arising from the same accident.
In Chiropractic Care Centers, Inc. v. Allstate Ins. Co., 2015 WL 5783605 (Mass. App. Div.), the Massachusetts Appellate Division held that Jimenez did not have authority to release the PIP claim because he had previously assigned the claim to Chiropractic and Allstate had notice of the assignment.
Allstate asserted that Jimenez falsely claimed in the release that there were no outstanding medical bills and that any such bills would be paid from the proceeds of the uninsured motorist benefit settlement. The court held that any recourse Allstate has for such statements is against Jimenez and does not affect the rights of Chiropractic.
The court also held that the release did not encompass PIP benefits because the release was specific to uninsured motorist benefits.