MRI Associates of America, LLC v. State Farm Fire & Casualty Co., 61 So. 3d 462

MRI Associates sought unpaid PIP benefits for two MRI scans performed for Ebba Register after a car accident, billing $1,707.33 and $1,816.17.
State Farm denied the claim after a paper peer review concluded the MRIs were not reasonable, related to the accident, or medically necessary, and challenged the charges under section 627.736(5).
MRI, under an assignment from Register, submitted records and a health insurance claim form totaling $3,523.50.
MRI sent a pre-suit demand under 627.736(11) showing the billed amounts and an 80% payment-discount column, but without stating a precise amount due.
County court granted MRI summary judgment, finding MRI satisfied prerequisites of § 627.736(5), and State Farm’s expert report could not support denial.
The circuit court reversed, relying on authorities to hold the demand premature and to require precise itemization of the amount due; the district court ultimately denied MRI’s petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the pre-suit demand was premature	MRI argues demand was proper under §627.736(11) as overdue and itemized.	State Farm argues demand was premature because no overdue status and amounts were not precisely stated.	Premature demand; not overdue and not precisely itemized.
Whether the insurer may rely on an expert report to deny a claim	MRI contends the report is not a valid basis for denial under §627.736(7)(a).	State Farm relies on the expert report to deny the claim.	The circuit court correctly analyzed admissibility; report cannot independently sustain denial if not properly considered.
Whether a health insurance claim form can satisfy the itemization requirement	MRI asserts the form suffices as the itemized statement required by §627.736(11) and §627.736(5)(d).	State Farm argues the form failed to specify exact amounts owed under the statute.	Itemization must specify exact amounts; the provided form did not meet precision requirements.
Whether the amount billed must be precise under the statute	MRI contends the statutory framework allows the claim to be pursued with the amounts billed.	State Farm contends precision is required to avoid gamesmanship and delay.	The statutory requirement mandates precise amounts early in the claims process.

Central Magnetic Imaging Open MRI of Plantation, Ltd. v. State Farm Fire and Cas. Ins. Co., 22 So. 3d 782 (Fla. 4th DCA 2009) (insurer may rely on proper reports within statutory framework for denial)
Menendez v. Progressive Express Ins. Co., 35 So. 3d 873 (Fla. 2010) (statutory requirements for PIP claims and presuit procedures clarified)