A New York appellate court has reversed the dismissal of personal injury claims from motor vehicle accident, ruling the injuries were unrelated to the crash. 

The Appellate Division, Second Department, issued its decision on September 16, 2026, in a case originally filed against Uber Technologies and the driver of the vehicle involved in the collision. 

At the center of the dispute is New York's no-fault threshold. Under Insurance Law § 5102(d), someone hurt in a car accident can only sue for damages beyond no-fault benefits if they can show a "serious injury" - one that fits specific statutory categories, including permanent consequential limitation of use or significant limitation of use of a body function or system. If the injury does not clear that bar, the lawsuit goes nowhere. 

The defendant moved for summary judgment, arguing the plaintiff's injuries did not qualify. The trial court in Queens County agreed and granted the motion in March 2025. 

The Second Department saw it differently. The court accepted that the defendant initially cleared the first hurdle, making a prima facie case that the injuries fell short of the serious injury standard. But the plaintiff came back with evidence of injuries to his cervical and lumbar spine, left shoulder, and left knee - enough to create genuine factual disputes about whether those injuries met the permanent consequential or significant limitation thresholds. 

Then came the bigger problem for the defense. The defendant never established that those four sets of injuries were unrelated to the accident. That gap was fatal. Without it, the usual next step in this framework - shifting the burden to the plaintiff to explain any break in medical treatment - never kicked in.

The order was reversed and the motion denied. The case moves forward. 

For no-fault claims teams and auto liability adjusters in New York, the practical point is sharp: a summary judgment motion on serious injury that skips causation on even one claimed body part can collapse entirely, no matter how strong the threshold argument looks on paper. 

The decision is a slip opinion, uncorrected and subject to revision before publication in the Official Reports.