THE PLASTIC SURGERY CENTER, PA VS. MALOUF CHEVROLET-CADILLAC, INC. THE PLASTIC SURGERY CENTER, PA VS. LEONE INDUSTRIES THE WOODS O.R., INC. VS. LEONE INDUSTRIES STEVEN J. PARAGIOUDAKIS, M.D. VS. CAFÉ BAYOU MARC MENKOWITZ, M.D. VS. CAFÉ BAYOU (DIVISION OF WORKERS' COMPENSATION) (CONSOLIDATED) (A-5597-16T1/A-5603-16T1/A-5604-16T1/A-0151-17T1/A-0152-17T1)
In 2012, the Legislature amended N.J.S.A. 34:15-15, granting the Division of Workers' Compensation exclusive jurisdiction over claims brought by medical providers for payment of services rendered to injured employees. These appeals questioned whether, through its silence, the Legislature intended – via this 2012 amendment – to apply the two-year statute of limitations, N.J.S.A. 34:15-51, contained in the Workers' Compensation Act, or whether the Legislature intended to leave things as they were and continue to apply the six-year statute of limitations for suits on contracts, N.J.S.A. 2A:14-1, to such claims. The court concluded that subjecting medical-provider claims to the two-year time-bar would be like jamming a square peg into a round hole, and that to reinterpret the two-year time-bar to fit such claims would require the reshaping of the edges of this square peg contrary to principles of judicial restraint. The court reversed the judgments that dismissed these medical-provider claims.