Perhaps no topic in recent no-fault practice has generated as much debate as the issue of what is necessary to satisfy a plaintiff assignee medical provider’s prima facie case.

Plaintiffs in no-fault practice, unlike any other area of New York practice, do not have a definitive answer as to what they must demonstrate to satisfy their prima facie case. This article attempts to discern what the different appellate courts have found constitutes a prima facie case, and whether there is a consensus within the courts as to this issue.