Millennium Diagnostic Imaging Center, Inc. v. State Farm Mutual Automobile Insurance
129 So. 3d 1086
| Fla. Dist. Ct. App. | 2013Background
- Millennium Diagnostic provided MRIs to three State Farm insureds (2010–2011) and received assignments of their PIP benefits; total charges under $15,000.
- State Farm questioned whether the services were lawful, reasonable, related, and medically necessary and could not verify facility accreditation.
- Pursuant to §627.736, State Farm served statutory information requests; Millennium did not produce the requested documentation.
- State Farm filed a discovery action under §627.736(6)(c) seeking a court order compelling compliance; the circuit court denied Millennium’s motion to dismiss and granted discovery.
- Millennium sought extraordinary relief from this Court via writs of prohibition and certiorari to quash the discovery order; the Court denied both petitions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prohibition is available to undo the discovery order | Millennium: prohibition appropriate to challenge court’s exercise of jurisdiction | State Farm: prohibition is preventative only and cannot undo an entered order | Court: prohibition not available to revoke an order already entered; denial granted |
| Whether the circuit court had subject-matter jurisdiction over the §627.736(6)(c) discovery action | Millennium: circuit court lacked jurisdiction because amount fell under county court monetary threshold | State Farm: circuit court has equity jurisdiction and concurrent jurisdiction with county court | Court: circuit court had jurisdiction; county and circuit courts share concurrent equity jurisdiction |
| Whether a §627.736(6)(c) discovery action is equitable or legal in nature | Millennium: discovery action is not an equitable claim | State Farm: action is equitable because it seeks an order to compel discovery | Court: the action is equitable; discovery orders are remedies directing a party to act, within equity jurisdiction |
| Whether certiorari relief was warranted | Millennium: certiorari should quash the discovery order | State Farm: Millennium failed to show irreparable harm or departure from essential requirements of law | Court: certiorari denied—Millennium did not allege or prove material injury or irreparable harm |
Key Cases Cited
- Dep’t of Children & Family Servs. v. Interest of J.C., 847 So.2d 487 (Fla. 3d DCA 2002) (extraordinary prohibition relief limited to preventing nonexisting judicial power)
- State ex rel. Sarasota Cnty. v. Boyer, 360 So.2d 388 (Fla. 1978) (prohibition is preventative, not corrective)
- Ortiz v. Fla. Parole Comm’n, 15 So.3d 941 (Fla. 3d DCA 2009) (reiterating prohibition’s preventative scope)
- Alexdex Corp. v. Nachon Enters., Inc., 641 So.2d 858 (Fla. 1994) (county and circuit courts share concurrent equity jurisdiction)
- MRI Servs., Inc. v. State Farm Mid. Auto. Ins. Co., 807 So.2d 783 (Fla. 2d DCA 2002) (recognizing §627.736 discovery actions in equity)
- State Farm Mut. Auto. Ins. Co. v. Green, 579 So.2d 402 (Fla. 5th DCA 1991) (distinguishing legal vs equitable actions by remedy sought)
- King Mountain Condo. Ass’n v. Gundlach, 425 So.2d 569 (Fla. 4th DCA 1982) (nature of breach and remedy determine law vs equity)
- George Vining & Sons, Inc. v. Jones, 498 So.2d 695 (Fla. 5th DCA 1986) (equity orders direct parties to do or refrain from specific acts)
- State Farm Mut. Auto. Ins. Co. v. Goldstein, 798 So.2d 807 (Fla. 4th DCA 2001) (addressing §627.736(6)(c) discovery without questioning circuit court jurisdiction)
- Kaminester v. State Farm Mut. Auto. Ins. Co., 775 So.2d 981 (Fla. 4th DCA 2000) (treating §627.736 discovery matters in equity)
- Kirlin v. Green, 955 So.2d 28 (Fla. 3d DCA 2007) (certiorari requires departure from essential requirements of law and irreparable harm)
- Nucci v. Nucci, 987 So.2d 135 (Fla. 2d DCA 2008) (material injury and irreparable harm are prerequisites for certiorari relief)