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United Automobile Insurance Co. v. Professional Medical Group, Inc.

Citations: 128 So. 3d 1; 2009 Fla. App. LEXIS 20030; 2009 WL 4934687Docket: No. 3D09-771

Court: District Court of Appeal of Florida; December 22, 2009; Florida; State Appellate Court

Narrative Opinion Summary

The petition for certiorari is granted in part, referencing precedents set in United Automobile Insurance Co. v. Santa Fe Medical Center and United Automobile Insurance Co. v. Garrido. The court quashes the circuit court’s appellate decision that deemed Dr. Goldberg’s peer review—a report asserting that the insured's medical treatment was neither reasonable nor necessary—as not constituting a “valid medical report” under section 627.736(7)(a) of the Florida Statutes. The court clarifies that the requirement for obtaining a valid medical report applies to the withdrawal, not the denial, of Personal Injury Protection (PIP) benefits. Consequently, the court's decision indicates that an insurer's obligation to secure a medical report is only relevant when withdrawing payment, not when denying it. The ruling is granted in part and quashed in part.

Legal Issues Addressed

Application of Section 627.736(7)(a) of the Florida Statutes

Application: The court clarifies that the statutory requirement for obtaining a valid medical report applies specifically to the withdrawal of Personal Injury Protection (PIP) benefits, not to their denial.

Reasoning: The court clarifies that the requirement for obtaining a valid medical report applies to the withdrawal, not the denial, of Personal Injury Protection (PIP) benefits.

Insurer's Obligation in Securing Medical Reports

Application: The decision establishes that an insurer is required to obtain a medical report only when withdrawing payment of PIP benefits, aligning with statutory interpretations.

Reasoning: Consequently, the court's decision indicates that an insurer's obligation to secure a medical report is only relevant when withdrawing payment, not when denying it.

Precedential Influence on Certiorari Decisions

Application: The court references previous decisions to grant certiorari in part, illustrating the impact of precedent in shaping judicial outcomes.

Reasoning: The petition for certiorari is granted in part, referencing precedents set in United Automobile Insurance Co. v. Santa Fe Medical Center and United Automobile Insurance Co. v. Garrido.

Validity of Medical Reports in Insurance Disputes

Application: The court quashes the prior appellate decision that deemed Dr. Goldberg’s peer review as not constituting a 'valid medical report' under the statute, reinforcing the criteria for such reports.

Reasoning: The court quashes the circuit court’s appellate decision that deemed Dr. Goldberg’s peer review—a report asserting that the insured's medical treatment was neither reasonable nor necessary—as not constituting a 'valid medical report' under section 627.736(7)(a) of the Florida Statutes.