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New Jersey Court Orders Lyft Insurer to Cover Pedestrian Injuries
A New Jersey appeals court ruled July 24 that Lyft’s insurer must provide personal injury protection (PIP) benefits to an uninsured pedestrian struck by a Lyft driver. The decision addressed whether a rideshare company’s liability insurance policy must provide no-fault medical coverage to an uninsured pedestrian injured by one of its drivers.
What Happened in the Lyft Insurance Case?
The case involved Lamar Boone, an uninsured pedestrian who was allegedly struck by Jean E. Zamor while Zamor was driving for Lyft. Boone did not own a motor vehicle or live with anyone who owned one, leaving him without other PIP coverage for his medical expenses.
Zamor’s vehicle was covered under a Liberty Mutual Business Auto policy issued to Lyft. The policy provided liability coverage but did not include PIP benefits for uninsured pedestrians.
Liberty Mutual denied Boone’s claim, arguing that New Jersey’s Transportation Network Company Safety and Regulatory Act (TNC Act) controls insurance requirements for rideshare companies and does not specifically require PIP coverage for pedestrians. Boone then sought benefits through the Unsatisfied Claim and Judgment Fund, administered by the New Jersey Property-Liability Insurance Guaranty Association (NJPLIGA), but that claim was also denied.
NJPLIGA argued that the vehicle was being used as a commercial rideshare vehicle and therefore was not an “automobile” under the fund’s statutes.
What Did the New Jersey Appeals Court Decide?
The Appellate Division sided with Boone and affirmed the lower court’s decision requiring Liberty Mutual to provide PIP benefits. The court held that New Jersey’s TNC law must be considered alongside other state insurance laws, including N.J.S.A. 17:28-1.3, which requires liability insurance policies issued on certain motor vehicles to provide PIP benefits to uninsured pedestrians injured by the named insured’s vehicle.
The court determined that nothing in the TNC Act eliminated those existing pedestrian protections. The judges also noted that the pedestrian-PIP requirements were already in place when the Legislature adopted the TNC Act in 2017.
The court rejected Liberty Mutual’s argument that the TNC Act exclusively governed insurance requirements for Lyft vehicles. Because the vehicle was being used as a rideshare vehicle and was therefore a “motor vehicle” rather than an “automobile” under the relevant statute, the court concluded that N.J.S.A. 17:28-1.3 required Liberty Mutual’s policy to include pedestrian PIP coverage.
The court ultimately held that Liberty Mutual was required to provide PIP benefits to Boone and that the Lyft policy had to be reformed to include the required coverage. The decision establishes that liability insurance policies issued to New Jersey transportation network companies must include PIP benefits for uninsured pedestrians injured by covered rideshare vehicles.
Need Help With an Insurance Claim in New Jersey? Contact Herold Law, P.A.
If you need guidance on evolving insurance requirements, our experienced New Jersey Insurance Lawyers at Herold Law, P.A. can help explain your rights and protect your interests. Call 908-679-5011 or contact us online to schedule a consultation. Located in Warren, we serve clients across New Jersey.
