An itemized bill or invoice, receipted or marked paid, for services or repairs of an amount not in excess of two thousand dollars is admissible in evidence and is prima facie evidence of the reasonable value and necessity of such services or repairs itemized therein in any civil action provided it bears a certification by the person, firm or corporation, or an authorized agent or employee thereof, rendering such services or making such repairs and charging for the same, and contains a verified statement that no part of the payment received therefor will be refunded to the debtor, and that the amounts itemized therein are the usual and customary rates charged for such services or repairs by the affiant or his employer; and provided further that a true copy of such itemized bill or invoice together with a notice of intention to introduce such bill or invoice into evidence pursuant to this rule is served upon each party at least ten days before the trial. No more than one bill or invoice from the same person, firm or corporation to the same debtor shall be admissible in evidence under this rule in the same action.
R 4533-a.Prima facie proof of damages.
Article 45. Evidence · Last amended 1968 · Last verified July 21, 2026
In one sentenceCPLR 4533-a admits a small itemized, receipted bill or invoice for services or repairs of no more than two thousand dollars as prima facie evidence of the reasonable value and necessity of what it itemizes, provided it is certified and accompanied by the required affidavit-style statement and served on every party at least ten days before trial.
Full Text of CPLR 4533-a
Plain-English Summary
Small repair and service bills, for a car repair, a plumbing job, a medical service, rarely justify the cost of calling the biller as a live witness. CPLR 4533-a lets a party skip that step for bills under a set dollar threshold. An itemized bill or invoice, receipted or marked paid, for services or repairs of an amount not exceeding two thousand dollars, is admissible and is prima facie evidence of the reasonable value and necessity of the itemized services or repairs.
Several conditions have to line up. The bill must carry a certification by the person, firm, or corporation that performed the work and is charging for it, or by an authorized agent or employee of that biller. That certification must include a verified statement that no part of the payment will be refunded to the debtor, guarding against kickback arrangements designed to inflate a damages claim, and a statement that the itemized amounts are the usual and customary rates the biller charges for that kind of work.
Procedurally, the proponent must serve a true copy of the bill, together with notice of intent to introduce it under this rule, on every party at least ten days before trial. And the statute caps how much of this shortcut any single biller gets in the same case: no more than one bill or invoice from the same person, firm, or corporation to the same debtor is admissible under this rule in the same action.
Frequently Asked Questions
What is the dollar limit for a bill admissible under CPLR 4533-a?
The itemized bill or invoice cannot exceed two thousand dollars.
What has to be certified on the bill for CPLR 4533-a to apply?
A certification by the biller, or an authorized agent or employee, containing a verified statement that no part of the payment will be refunded to the debtor and that the itemized amounts are the usual and customary rates charged for that kind of service or repair.
How much notice do I have to give before trial to use CPLR 4533-a?
A true copy of the bill and a notice of intention to introduce it must be served on each party at least ten days before trial.
Can I introduce more than one bill from the same repair shop under CPLR 4533-a?
No. The statute limits admissibility to no more than one bill or invoice from the same person, firm, or corporation to the same debtor in the same action.
What does a CPLR 4533-a bill prove once it is admitted?
It is prima facie evidence of the reasonable value and necessity of the services or repairs it itemizes, though the opposing party can still offer contrary evidence.
Why does CPLR 4533-a require a no-refund certification?
To prevent a biller and debtor from inflating an invoice with an understanding that part of the payment will be kicked back, which would undercut the bill's reliability as proof of reasonable value.
Amendment History
Add, L 1966, ch 263; amd by the Judicial Conference, eff Sept 1, 1968.
Source & verification. Provision text, History, and Advisory
Committee Notes are reproduced verbatim from the Consolidated Laws of New York.
Last verified July 21, 2026.
· Official source
Also known as: itemized bill prima facie evidence damagestwo thousand dollar repair bill evidencecertified invoice admissible New Yorksmall claims repair bill evidence rule