Laboratory Corporation of America v. Patty Davis, etc. & Sheridan Radiology Services of Pinellas, Inc. v. Patty Davis, etc., 339 So.3d 318

Patty Davis was injured at work and received workers’ compensation medical care from Sheridan and Labcorp.
Sheridan and Labcorp subsequently billed Davis directly; Davis sued both under the Florida Consumer Collection Practices Act (FCCPA), alleging unlawful attempts to collect an illegitimate debt.
The providers moved to dismiss, arguing Florida’s Workers’ Compensation Law (WCL) vests exclusive jurisdiction over reimbursement matters in the Department of Financial Services (DFS) (§440.13(11)(c)), so circuit courts lacked jurisdiction.
Trial courts dismissed; the Second District reversed, holding the WCL exclusivity provision did not bar the FCCPA suits and certified a question of great public importance.
The Florida Supreme Court answered the certified question: §440.13(11)(c) does not preclude circuit court jurisdiction over FCCPA §559.77 claims based on billing an injured worker.
The Court reasoned “reimbursement” in the WCL refers to carrier-to-provider payments; the DFS exclusivity covers carrier–provider reimbursement disputes, not provider billing to injured workers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §440.13(11)(c)’s grant of exclusive jurisdiction to DFS over “any matters concerning reimbursement” precludes circuit-court FCCPA suits by injured workers	Davis: “reimbursement” means carrier-to-provider payments; provider billing to worker is not reimbursement and so not within DFS exclusivity	Providers: “any matters concerning reimbursement” is broad; reimbursement includes any payment or collection related to medical services, so DFS has exclusive jurisdiction and circuit courts lack jurisdiction	Held: No. “Reimbursement” in the WCL means payments from carrier to provider; §440.13(11)(c) covers carrier–provider disputes, not provider billing of injured workers; circuit courts retain jurisdiction over FCCPA claims

Davis v. Sheridan Healthcare, Inc., 281 So. 3d 1259 (Fla. 2d DCA 2019) (Second DCA reversed dismissals and certified the question to the Florida Supreme Court)
Lopez v. Hall, 233 So. 3d 451 (Fla. 2018) (standard of review: de novo for statutory interpretation)
Ham v. Portfolio Recovery Assocs., LLC, 308 So. 3d 942 (Fla. 2020) (textualist approach; meaning of statutory words in context guides interpretation)
Deal v. United States, 508 U.S. 129 (1993) (a word’s meaning must be drawn from its statutory context)