Casinelli v. Manglapus

I have a different view of the legislative intent animating the provisions of the New Jersey Automobile Insurance Cost Reduction Act (AICRA), L.1998, c. 21 and c. 22 generally, and the physician certification requirement specifically. AICRA added that requirement to the other conditions that an accident victim must satisfy to pursue a tort recovery under the limitation on lawsuit provisions set forth in N.J.S.A. 39:6A-8a. In this matter, the Appellate Division held that the plaintiffs failure to comply with the physician certification requirement could result in the dismissal without…