State Farm Mutual Automobile Insurance Company, Below-Appellant v. Melvin Davis, Below-Appellee

Summary

The Court reversed the Superior Court’s judgment because the plaintiff’s PIP benefits had already been exhausted through an unchallenged assignment and payments to healthcare providers before he requested that benefits be reserved for lost wages. The Court held that the statutory reservation issue was therefore moot and declined to decide the underlying statutory-construction question. The Court also held that the Superior Court erred by sua sponte deciding the validity of an assignment that had not been challenged or litigated.