The New Jersey Automobile Insurance Cost Reduction Act ( AICRA) bars uninsured drivers from suing for personal injuries sustained in automobile accidents. In Aronberg v. Tolbert, the trial court granted summary judgment to the defendant’s dismissing a survival action brought by an uninsured decedent’s estate, but denied summary judgment as to the wrongful death action brought by his heirs. The Appellate Division affirmed, concluding that while the AICRA statutory bar may apply to survival actions brought on behalf of the decedent, it did not apply to a wrongful death action seeking damages for losses suffered by the decedent’s heirs.
