Bonita Beaumont v. Muluken Zeru

Summary

The Kentucky Supreme Court held that a payment for personal injury protection (PIP) purposes occurs when the insurer issues a check, and the date of the last payment is the date the last check—whether an original or replacement—is sent. Accordingly, the two‑year limitations period began on September 25, 2009, making Beaumont’s September 21, 2011 filing timely, so the court reversed the summary judgment and remanded for further proceedings.