Lang v. City of New York
This concurring memorandum addresses a personal injury action brought by plaintiffs Lang and Pokorny against defendant Lawrence and municipal defendants following a severe automobile accident. The jury initially apportioned culpability and awarded damages, but a dispute arose regarding a no-fault carrier's lien on the plaintiffs' recovery. Special Term had vacated this lien. Judge O'Connor concurs with the majority's decision to reverse the judgment and grant a new trial solely on the issue of damages. This reversal is based on the trial court's improper exclusion of evidence concerning plaintiffs' basic economic loss against the municipal defendants, who were not considered "covered" persons under the relevant insurance act. Furthermore, the memorandum delves into the broader legal principle of insurance liens, arguing that such liens should attach to any recovery, not just basic economic loss, drawing parallels between the Insurance Law and the Workers' Compensation Law.