Kurt Lindstrom, by His Guardian Ad Litem, George K. Lindstrom, and George K. Lindstrom

Summary

The Supreme Court of New Jersey reversed the trial court’s summary judgment, holding that injuries from a random drive‑by shooting where the bullet was propelled from an automobile satisfy the substantial‑nexus test and are covered by personal‑injury‑protection under N.J.S.A. 39:6A‑4. The decision rests on a liberal construction of the statute, the foreseeability of such assaults, and the requirement that the automobile be a central factor. The Court limited the holding to random drive‑by shootings and declined to create general crime insurance. Justice Pollock dissented, arguing the statute does not cover such incidents.