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Grullon v. Chang Ok Chu

Citations: 240 A.D.2d 367; 657 N.Y.S.2d 776; 1997 N.Y. App. Div. LEXIS 5814

Court: Appellate Division of the Supreme Court of the State of New York; June 2, 1997; New York; State Appellate Court

Narrative Opinion Summary

In an appeal regarding a personal injury case, the defendants contested a Supreme Court order from November 26, 1996, which vacated an earlier order from October 15, 1996, that had dismissed the plaintiff's complaint due to her failure to appear at a scheduled hearing. The defendants argued that the dismissal was warranted as the plaintiff did not meet the threshold of demonstrating a serious injury as defined by Insurance Law § 5102(d). The court found otherwise, noting that the plaintiff submitted an affidavit from a physician indicating she had a significant and permanent restriction in the motion of her lumbosacral spine, quantified as 35 to 40 degrees. This medical evidence was deemed adequate to establish a prima facie case of serious injury, thereby justifying the vacating of the initial dismissal. The appellate court affirmed the Supreme Court's decision, with all justices concurring.

Legal Issues Addressed

Prima Facie Case of Serious Injury

Application: The plaintiff's submission of medical evidence showing a quantifiable restriction in movement was sufficient to establish a prima facie case of serious injury.

Reasoning: This medical evidence was deemed adequate to establish a prima facie case of serious injury, thereby justifying the vacating of the initial dismissal.

Reinstatement of Dismissed Complaint

Application: The court vacated the dismissal of the plaintiff's complaint because she provided sufficient evidence to establish a prima facie case of serious injury.

Reasoning: The court found otherwise, noting that the plaintiff submitted an affidavit from a physician indicating she had a significant and permanent restriction in the motion of her lumbosacral spine, quantified as 35 to 40 degrees.

Serious Injury Threshold under Insurance Law § 5102(d)

Application: The plaintiff successfully demonstrated that her injury met the serious injury threshold through medical evidence, which was sufficient to reinstate her complaint.

Reasoning: The defendants argued that the dismissal was warranted as the plaintiff did not meet the threshold of demonstrating a serious injury as defined by Insurance Law § 5102(d).