Two state supreme courts and one published California Court of Appeal opinion shaped the practical edges of personal-injury practice this week. The New Jersey Supreme Court's decision in Murray v. Punina, issued on May 11, narrowed what plaintiffs can board on future medicals when PIP remains collectible. A California Court of Appeal panel published Sargenti v. City of Long Beach on May 15, putting an asphalt patch and a sidewalk-to-bike-lane transition at the center of a Government Code section 835 dangerous-condition analysis. And in California, the practical fallout from SB 371's rideshare UM/UIM cut continues to ripple through case selection at firms that book volume on app-on collisions.
New Jersey: Murray v. Punina and the limits of boarding future medicals
The Supreme Court of New Jersey blocked recovery of future medical expenses in a PI trial where those expenses fell within the plaintiff's elected PIP coverage. In Murray v. Punina, the plaintiff's expert opined that future treatment would cost between $42,000 and $160,000. The jury awarded $100,000 for future medicals. The court vacated that line item, reasoning that future bills still legally collectible as PIP benefits cannot also be presented to a jury as recoverable damages. The court characterized the result as preventing double recovery, not capping plaintiff rights.
The legislative reversal of Haines v. Taft remains good law, so plaintiffs with unpaid bills above their PIP election can still seek those amounts. The narrow rule in Murray applies to projected future treatment that remains within PIP. In practice, that means PI counsel in New Jersey need to confirm two things before a trial brief is filed: the client's PIP election amount and the running PIP balance at the time of trial. Boarding numbers above the PIP cushion is fine. Boarding numbers a carrier would still pay is now error.
Defense counsel in New Jersey are already adjusting motions in limine, asking trial courts to exclude any future-medicals testimony that falls below the PIP cap absent a stipulation that PIP has been exhausted. Plaintiff firms should expect this objection at the pretrial conference and have an exhaustion letter from the PIP carrier ready, along with a forward-looking projection from the treating physician that distinguishes treatment likely to be billed against the remaining PIP layer from treatment that would push the client over the cap.
One practical workaround worth flagging: in cases where the plaintiff is approaching the PIP cap during the pendency of litigation, a strategic decision about whether to accelerate or delay certain treatments may have a meaningful effect on boardable damages at trial. That is a conversation between treating physicians and case managers, not one driven by trial strategy alone, but it is now part of the calculus.
For deeper case-law coverage of the Murray decision and its interaction with prior Haines/Taft jurisprudence, see prior reporting on the case-law and settlements desk.
California: Sargenti v. City of Long Beach
On May 15, Division Eight of the Second District published its opinion in Sargenti v. City of Long Beach (Case No. B340275). The plaintiff rented an electric scooter, hit an asphalt patch while moving from the sidewalk to a bicycle lane, and sued the city under the dangerous-condition-of-public-property theory.
The panel affirmed summary judgment for the city, focusing on the constructive-notice prong of Government Code section 835. The city's superintendent walked the court through Long Beach's complaint-intake systems: phone-call logs, the web complaint portal, the 311 app, and routine inspections by Public Works crews. The record showed no service requests for the location and no prior complaints about the asphalt patch. The plaintiff offered no evidence the city should have discovered the condition before the incident.
Two practical takeaways. First, in any dangerous-condition case against a California public entity, the plaintiff's discovery plan should front-load a Public Records Act request for all complaint logs, work orders, and inspection records for a one-quarter-mile radius around the incident location for at least three years pre-incident. If those records are thin, the case lives or dies on actual notice or a creator-employee theory. Second, micromobility cases will keep landing in plaintiff inboxes. Scooter-and-bike-lane geometry creates predictable transition hazards, and cities have predictable notice gaps. Building the constructive-notice record early is the difference between a defensible settlement value and an affirmed summary judgment.
California rideshare: SB 371 case-selection effects
SB 371 took effect January 1, 2026. The bill cut the UM/UIM coverage Uber and Lyft must carry for app-on, no-ride-accepted collisions from a $1 million layer to statutory minimums of $60,000 per person and $300,000 per accident. Five months in, the practical effect on plaintiff intake is visible.
PI firms with high rideshare volume are now triaging at intake based on phase. Phase 2 and Phase 3 cases (accepted ride, passenger on board, or driver en route to pickup) still sit behind the $1 million liability layer. Phase 1 cases (app on, no ride) now sit behind the new $60,000 and $300,000 floor. For a Phase 1 case with cervical fusion damages, the math has changed. Firms that built operational throughput around the prior $1 million Phase 1 layer are seeing case values for that phase drop by an order of magnitude.
The intake-screening question for Phase 1 cases is now whether the rideshare driver carries personal auto coverage that activates when the app is on but no ride is accepted. In California, most personal auto policies still exclude commercial use. A driver who logged in for the night and was on her way home from a Phase 1 collision may have neither commercial coverage above the new minimums nor personal coverage that responds. That is a thin recovery layer, and intake should be screening for it.
For practice-area resources on rideshare claims and auto-accident strategy more broadly, the firm's auto-accidents desk has been tracking the SB 371 implementation since the governor signed the bill last fall.
Verdict roundup
Notable verdicts this quarter that practitioners should be aware of:
- $71M premises-liability verdict, Prince George's County, Maryland. A jury awarded more than $71 million to a tenant who suffered spinal fractures and permanent paralysis after jumping from a second-story apartment during a fire at the Lilly Garden complex in Lanham. The building had no functioning sprinklers and no audible alarm. The verdict is one of the largest premises-liability awards in Maryland this cycle and underscores the continued evidentiary weight of life-safety code violations in catastrophic-injury cases.
- $6M Meta/YouTube social-media addiction verdict, California. A jury found for a 20-year-old plaintiff against both platforms on design-defect and failure-to-warn theories. The verdict adds to the growing pile of plaintiff wins in the JCCP and federal MDL coordinated social-media addiction proceedings, and bellwether selection in the coordinated docket is being closely watched by both sides.
- $3.4M slip-and-fall verdict, Las Vegas. A casino patron who slipped on a wet marble floor in 2018 and required cervical injections, ablations, a nerve-stimulator implant, and surgery secured a $3.4 million verdict. The case is a reminder that even older slip-and-fall files with complex medical specials can still produce seven-figure outcomes when the treatment timeline is well-documented.
- $375M Meta verdict, New Mexico. A jury found Meta liable for misleading users about platform safety and putting children at risk. The verdict, though likely to be reduced post-trial or on appeal, signals continued jury appetite for large punitive components in tech-platform liability cases.
What to watch next week
Three items on the calendar. The California Supreme Court's docket includes oral argument on a published Court of Appeal opinion addressing the admissibility of seatbelt-use evidence as a comparative-fault offset in catastrophic-injury cases. Several state legislatures are entering the final two weeks of their session, with active tort-reform bills moving in Georgia and Pennsylvania that would tighten venue rules and impose new caps on noneconomic damages. And the federal MDL judge handling the Tylenol-autism coordinated proceeding has a Daubert ruling expected before Memorial Day that will materially affect case valuations across the docket.
On the regulatory side, NHTSA's revised event-data-recorder rule published last November is now in its public-comment window for the implementation guidance, with the comment period closing in early June. Plaintiff and defense bars are both filing comments on data-retention windows and standardized download formats. The final rule will shape what EDR data can be extracted, in what format, and on what timeline in any future collision case.
PI firm operators tracking how these developments affect intake mix, lien posture, and case-team staffing can find ongoing benchmark coverage on the practice-operations desk.