Millennium Diagnostic Imaging Center, Inc. v. State Farm Mutual Automobile Insurance
Docket: No. 3D12-1074
Court: District Court of Appeal of Florida; September 30, 2013; Florida; State Appellate Court
Millennium Diagnostic Imaging Center, Inc. sought a writ of prohibition or, alternatively, a writ of certiorari to quash a circuit court discovery order. The court denied both petitions. Prohibition is inappropriate as it cannot revoke an already entered order; it serves as a preventative remedy, not a corrective one. Millennium had provided MRI services to three insureds of State Farm Mutual Automobile Insurance Company, with a total cost under $15,000. After the insureds assigned their PIP benefits to Millennium, the company sought payment from State Farm, which investigated the claims for legality, reasonableness, and medical necessity. State Farm's inability to verify the accreditation of Millennium's facilities led to statutory requests for documentation, which Millennium failed to provide. Subsequently, State Farm initiated a discovery action. Millennium's motion to dismiss, arguing lack of jurisdiction and inappropriate scope of requests, was denied by the circuit court, which also granted State Farm's discovery request. Millennium's assertion that the circuit court lacked jurisdiction was refuted; both the county and circuit courts have concurrent equity jurisdiction in these matters, thus supporting the circuit court’s authority to hear the discovery action.
A county court possesses equity jurisdiction over actions for discovery under section 627.736(6)(c) as long as the amount in controversy does not exceed the county court's jurisdictional limit, rejecting the notion that only circuit courts hold such jurisdiction. State Farm's action for discovery is classified as equitable, not legal. The distinction between legal and equitable actions is based on the nature of the breach and the remedy sought, with legal actions typically seeking monetary damages, while equitable actions seek specific directives. Florida courts have recognized section 627.736(6)(c) actions as equitable, affirming that the nature of the breach involves statutory compliance by medical providers with discovery requests from insurers. The remedy under section 627.736(6)(c) is to compel compliance, which is inherently equitable. Although State Farm's remedy is statutory, such codification does not change its equitable nature. Consequently, the circuit court properly exercised its equity jurisdiction in ruling on the discovery action. Millennium's request for a writ of certiorari to quash the circuit court’s order was denied because Millennium failed to demonstrate material injury or irreparable harm, which are necessary for certiorari relief. State Farm's motion to convert the writ proceeding to a final appeal was also denied, with instructions to address the subject matter jurisdiction of the writ.
