MONMOUTH MEDICAL CENTER VS. STATE FARM INDEMNITY COMPANY SAINT BARNABAS MEDICAL CENTER VS. STATE FARM INDEMNITY COMPANY (L-2482-17 AND L-0126-18, MORRIS COUNTY AND STATEWIDE) (CONSOLIDATED) (A-3004-17T1/A-4208-17T1)
In these back-to-back appeals, State Farm Indemnity Company (State Farm) appeals from two trial court orders that vacated awards entered by dispute resolution professionals (DRP) pursuant to the Alternative Procedure for Dispute Resolution Act (APDRA), N.J.S.A. 2A:23A-1 to -30, in connection with payment for out-patient hospital services provided to two claimants involved in separate automobile accidents. In each appeal, the trial court entered a modified judgment against State Farm, finding that the DRP committed prejudicial error. The court determined that the trial court properly exercised the authority granted to it under the APDRA, adhered to the statutory grounds in vacating the DRPs' awards, and provided rational explanations of how the respective DRPs committed prejudicial error within the meaning of N.J.S.A. 2A:23A-13(c)(5). Because there was no principled reason for the exercise of the court's supervisory jurisdiction, or any unusual circumstances where public policy required the court's intervention, the court adhered to the strictures of N.J.S.A.2A:23A-18(b), barring further appeals or reviews of trial court judgments, and dismissed the appeals.