January 2023 – Florida Justice Reform Institute

Court ruling casts doubt on ‘sue first, discover second’ business model

January 26, 2023/in Florida Record

FLORIDA RECORD

Florida Justice Reform Institute President William Large agreed with the appeals court decision. | Florida Justice Reform Institute

By Michael Carroll – Jan 26, 2023

A Florida appeals court has pushed back on a company’s application of a little-used legal practice and cast a shadow on the business practices it uses to secure Medicare reimbursements.

The Third District Court of Appeal on Jan. 11 affirmed a trial court’s dismissal of a complaint filed by MSP Recovery Inc., which works to secure reimbursement recovery on Medicare and Medicaid claims. The lawsuit was filed against Coloplast Corp., which manufactures and sells surgical mesh products that MSP contends caused injuries to some Florida residents.

The appeals court affirmed the trial court’s dismissal order of MSP’s second amended complaint but did not comment in detail about the trial court’s finding that MSP failed to state a cause of action for a pure bill of discovery. That’s a rarely used legal action which seeks the disclosure of facts and information known to a defendant. The lower court concluded that it lacked jurisdiction over Coloplast.

“The appellate court was correct to affirm the dismissal of the complaint,” William Large, president of the Florida Justice Reform Institute, said in an email to the Florida Record. “Litigation should work as follows: sue first, discover second. MSP has a business model of discover first, sue second. That business model is no longer tenable in Florida.”

MSP argued that the trial court had personal jurisdiction over Coloplast based on provisions of Florida’s long-arm statute, which grants state courts authority over defendants in other states provided the defendants take part in “substantial” activities in Florida.

MSP also alleged that Coloplast caused personal injury to state residents as well as torts. But the appeals court rejected those arguments, saying Coloplast did not “commit any torts against Medicare individually” and describing the lawsuit as a Medicare reimbursement case as opposed to a personal injury action.

“MSP Recovery is nothing more than a litigation shell company,” Large said. “It provides no medical or insurance services to Medicare beneficiaries. MSP Recovery acquires claims from its assignors and utilizes its data analytics services to identify alleged improper payments for health care services.”

He also agreed with the appeals court that MSP practices failed to establish jurisdiction under Florida law.

“In this case, MSP has conflated the alleged physical injuries suffered by individuals, who were not parties to the case, with the alleged financial injuries that MSP claims to have been assigned,” Large said. “This is insufficient to secure jurisdiction under Florida’s long-arm statute.”

https://flarecord.com/stories/639057794-court-ruling-casts-doubt-on-sue-first-discover-second-business-model

MSP Recovery Dodged Ruling on What Attorneys Called Its Go-To Litigation Tactic

January 17, 2023/in Daily Business Review

(l-r) Third DCA Chief Judge Ivan F. Fernandez, and Judges Bronwyn C. Miller and Alexander S. Bokor (Courtesy photos)

January 17, 2023 – Michael A. Mora

“Litigation should work as follows: sue first, discover second. MSP has a business model of discover first, sue second. That business model is no longer tenable in Florida,” William Large, president of the Florida Justice Reform Institute, argued.

What You Need to Know

• An appellate court in Florida ruled against appellant on jurisdictional grounds.

• The appellate court avoided ruling on whether appellant correctly stated a cause of action for a pure bill of discovery.
• An amicus brief challenged whether the appellant’s business model is tenable, due to unfavorable rulings on its use of the pure bill of discovery tactic.

Florida’s Third District Court of Appeal delivered a blow against a subsidiary of a public company in a Medicare reimbursement case that some attorneys said also revealed cracks in its multibillion-dollar business model.

William Large, the Florida Justice Reform Institute president, filed an amicus brief in support of defendant, Coloplast Corp., taking a position adverse to plaintiffs, including MSP Recovery Claims Series LLC. The Third DCA affirmed Miami-Dade Circuit Judge Mark Blumstein’s ruling to dismiss MSP’s second amended complaint and incorporated memorandum of law with prejudice.

William Large, President of the Florida Justice Reform Institute

And Large said the personal-jurisdiction ruling “was more of a threshold issue,” rather than whether the complaint correctly stated a cause of action for a pure bill of discovery.

Still, since the lower court ruling denied plaintiffs’ entitlement to a pure bill of discovery, that could be bad news for MSP, as attorneys claimed that the company heavily relied on that litigation tactic to win cases.

“While the Third DCA didn’t create precedent on the point, the trial court’s ruling still helps, and will likely be used as persuasive authority in future attempts to use a pure bill of discovery,” Large said in a statement. “Litigation should work as follows: Sue first, discover second. MSP has a business model of discover first, sue second. That business model is no longer tenable in Florida.”

‘Exclusive and Novel Case Approach’

However, Janpaul Portal, of counsel at the MSP Recovery Law Firm who represented MSP, said the Third DCA in Coloplast agreed, in part, with their position that the lower court exceeded its authority on the issue before it, by ruling on the pleading requirements to maintain a pure bill of discovery in this case.

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“While other issues revolving around jurisdiction are fact-specific to the defendants in the case, MSP established the necessary substantive elements of a pure bill complaint,” Portal said. “MSP’s exclusive and novel case approach of employing proprietary data analytics, continues to be successful. By harnessing this technology, we will continue to pursue just results for our clients and accountability by responsible parties.”

Read the Opinion:

The underlying case involved pelvic surgical mesh products that Coloplast designed, manufactured, and sold, which caused several Floridians to sustain personal injuries, according to court documents.

Meanwhile, MSP’s assignors are Medicare Advantage organizations and related Medicare entities that provided comprehensive healthcare coverage for their Medicare beneficiaries in the Sunshine State, per court documents. Medicare paid for medical care and treatment that the Florida enrollees received to treat injuries resulting from these mesh products.

When MSP filed its second amended complaint for a pure bill of discovery against Coloplast in which plaintiff sought reimbursement of the claims paid by Medicare, defendant successfully moved to dismiss based upon two claims. These claims were that the trial court lacked personal jurisdiction and that MSP was not entitled to a pure bill of discovery.

On appeal, MSP argued that the trial court had personal jurisdiction over Coloplast based on three provisions of the Florida long-arm statute: “section 48.193(1)(a)(6), Coloplast caused personal injury; section 48.193(1)(a)(2), Coloplast committed torts; and section 48.193(1)(a)(1), Coloplast engaged in a business or business venture.”

Now, MSP struck out on all three arguments before Third DCA Chief Judge Ivan F. Fernandez, and his colleagues on the bench, Judges Bronwyn C. Miller and Alexander S. Bokor.

The Third District Court of Appeal

Among the reasons the Third DCA provided was that “this case is a Medicare reimbursement case, not a personal injury action.”

The Third DCA found that MSP’s cause of action did not substantively connect to the personal injury suffered by Florida residents.

As a result, the appellate court concluded that the economic damages suffered by plaintiff did not fall within Florida’s long-arm statute.

And the Third DCA applied the same analysis to plaintiffs’ claim of torts that justified application of Florida’s long-arm statute, by concluding that Coloplast did not commit any torts against Medicare individually. Finally, MSP itself failed to provide any facts supporting its argument that personal jurisdiction over Coloplast was warranted based upon it engaging in a business in the Sunshine State, the panel found.

Meanwhile, the Third DCA avoided the circuit court ruling that MSP failed to state a cause of action. Still, Williams, the Florida Justice Reform president—joined in the amicus by the U.S. Chamber of Commerce and the Pharmaceutical Research and Manufacturers of America—said in a brief that courts have lost patience with the alleged tactic.

Williams argued that MSP failed to abide by basic pre-filing diligence and pleading requirements necessary to substantiate the pure bill of discovery “for strategic business reasons,” which could limit future investor returns, if judges limit the tactic to its original intention, for “exceptional purposes.”

“This lawsuit mirrors scores like it filed in federal courts throughout the country that have all the earmarks of abusive litigation and indeed have drawn intense criticism from many a federal judge,” the U.S. Seventh Circuit Court of Appeals previously ruled against MSP, as cited in the brief. “The plaintiffs should think hard before risking a third strike within our circuit.”

https://www.law.com/dailybusinessreview/2023/01/17/msp-recovery-dodged-ruling-on-what-attorneys-called-its-go-to-litigation-tactic/

Florida’s high court rejects ‘excessive’ $16 million damages award in wrongful death case

January 10, 2023/in Florida Record

FLORIDA RECORD

Friday, January 13, 2023

Florida Justice Reform Institute President William Large called the state Supreme Court ruling a victory for textualism. | Florida Justice Reform Institute

By Michael Carroll – Jan 10, 2023

The Florida Supreme Court has struck down a $16 million punitive damages award in a wrongful death case, concluding that the award was out of sync with the jury’s compensatory damages award of just $150,000.

In a Jan. 5 ruling in the case of Brinda Coates vs. R.J. Reynolds Tobacco Co., the high court said trial courts abuse their discretion when they reject a party’s request to reduce punitive damages awards which appear unreasonable when compared with compensatory damages and the plaintiff’s injury.

In turn, the state Supreme Court affirmed a state appeals court’s ruling in the case, in which R.J. Reynolds was accused of being partly liable for the death of Coates’ sister, Lois Stucky, as a result of Stucky’s use of the company’s tobacco products.

“We approve the Fifth District’s decision reversing the punitive damages award and remanding for further proceedings to the extent the district court’s decision is consistent with this opinion,” the Supreme Court’s opinion states.

The Florida Justice Reform Institute (FJRI) and American Tort Reform Association (ATRA) view the high court’s decision as a victory for the rule of law.

“As the court noted in its opinion, ‘judicial discretion must be constrained by statutory criteria in determining whether an award is excessive,’ ” William Large, FJRI’s president, said in a statement emailed to the Florida Record. “This is a huge win for textualism and the notion that the judiciary’s role is to say what the law is and not what it should be.”

The FJRI, ATRA and the U.S. Chamber of Commerce previously filed an amicus brief in the case. The brief argues that a 1997 state law makes a punitive damages award greater than three times the compensatory damages award “presumptively invalid.” In the Coates case, the ratio of the two awards was 106.7 to 1.

The high court did acknowledge the possibility that a trial judge could make a finding that a punitive damages award reasonably exceeds the 3:1 ratio based on the facts and circumstances of a case. But such a finding has to show a reasonable relationship between “the amount of damages proved and the injury suffered,” the justices said.

The Record is owned by the U.S. Chamber of Commerce’s Institute for Legal Reform.

https://flarecord.com/stories/638662238-florida-s-high-court-rejects-excessive-16-million-damages-award-in-wrongful-death-case

“Huge Win”

January 8, 2023/in Florida Politics

January 8, 2023

The Florida Supreme Court this week answered a certified question from Florida’s 5th District Court of Appeal on relative damage awards in a tobacco-related wrongful death case.

The case, Coates v. R.J. Reynolds Tobacco Co., saw a jury award the plaintiff $150,000 in compensatory damages and $16 million in punitive damages, which are meant to punish defendants and serve as a deterrent for others.

William Large and the FJRI earned a major win this week.
Image via Colin Hackley.

The Florida Justice Reform Institute (FJRI), joined by the U.S. Chamber of Commerce and the American Tort Reform Association, previously filed an amicus brief in the case.

In its amicus, FJRI argued that “the 1997 version of the statutory cap found in section 768.73(1), Florida Statutes (1997) (the version applicable to this case), makes an award of punitive damages above the 3:1 ratio presumptively invalid.”

After the high court agreed, FJRI President William Large issued a celebratory statement.

“As the Court noted in its opinion, ‘judicial discretion must be constrained by statutory criteria in determining whether an award is excessive.’ This is a huge win for textualism and the notion that the judiciary’s role is to say what the law is and not what it should be,” he said.

https://floridapolitics.cmail20.com/t/i-e-qddddtt-trlttliyt-y/

Florida High Court Upholds Slashing of Punitive Damage Award in Tobacco Case

January 8, 2023/in The Insurance Journal

By William Rabb | January 8, 2023

The Florida Supreme Court has struck down $16 million in punitive damages against R.J. Reynolds Tobacco Co. as “excessive,” a decision that could bode well for insurers and businesses relying on courts to interpret state law strictly as written.

“Text matters,” said William Large, president of the Florida Justice Reform Institute, which filed an amicus brief supporting the tobacco company’s side in the case. “This is a victory for textualism. It’s important for all civil justice cases.”

Florida law dictates that punitive damages can be no greater than four times the compensatory damages awarded in a lawsuit, in most cases. At the time that this case, Brinda Coates vs. R.J. Reynolds, was heard at trial, the statutory ratio was 3:1. An Orange County jury granted $150,000 to the family of a woman who died after years of cigarette smoking, but then awarded $16 million in punitive damages – more than the plaintiff had asked for.

That was a ratio of 107 to 1 – far out of line with the Florida statute, Reynolds and amicus briefs argued. The Florida 5th District Court of Appeal last year agreed and remanded the case back to the trial court. But it also asked the Supreme Court to weigh in on when, exactly, courts can agree to a request to trim hefty punitive amounts.

Large

The named plaintiff is the sister of deceased smoker Lois Stucky, and represents Stucky’s estate and grown children. Coates’ attorneys argued that Florida law gives juries and courts wiggle room to allow higher punitive amounts in some circumstances. Consideration in this case should be given to the fact that Stucky’s suit began as a wrongful-death case and under the vagaries of Florida law, compensatory damages in those cases can be somewhat limited for surviving family members. That artificially limits punitive damages, the plaintiffs argued.

The majority of the justices disagreed, noting that the ratio rule is no different in death cases, and that the trial court had erred in allowing the $16 million as punishment.

“In this case, because no reasonable trial court could have found that the $16 million punitive damages award bears a reasonable relation to the $150,000 net compensatory damages award and the injury suffered by Ms. Stucky’s survivors, the Fifth District correctly reversed the excessive punitive damages award and remanded for further proceedings,” reads the Supreme Court majority opinion, written by Justice Ricky Polston.

The trial court now can allow no more than $450,000 in a punitive award, in keeping with the 3:1 ratio.

On the surface, the Coates decision may seem to fly in the face of other states’ courts that have upheld large awards against tobacco companies and that of a six-year-old opinion by the Florida Supreme Court. In Schoeff vs. R.J. Reynolds, the Florida justices in 2017 affirmed $30 million in punitive damages for the family of a smoker who died. In that case, though, the jury had allowed $10.5 million in compensatory damages, keeping the punitive amount within the three-to-one ratio.

Coates’ attorneys, including John Mills, of Jacksonville, noted that the compensatory damages in Schoeff were based on different circumstances, and the two cases give R.J. Reynolds different punishments for the same deadly offense.

“The sole reason for this disparity had nothing to do with RJR’s conduct or circumstances; the district court found that the ‘actual dollar amount of the punitive damage award’ was not excessive and was fully supported by RJR’s misconduct,” Coates’ lawyers, including John Mills, of Jacksonville, wrote. “Nonetheless, it held that the law required RJR receive substantially less punishment for killing Ms. Stucky than for killing Mr. Schoeff, based solely on the amount of the compensatory damages awarded to their respective survivors.”

In Schoeff, the deceased smoker left behind a spouse, resulting in higher compensatory damages. In Coates, the victim was divorced and had no spouse or young children.

In a sharp dissenting opinion in Coates, Justice Jorge Labarga said the majority’s decision essentially mocks the rationale behind punitive damages and undercuts a jury’s deliberations.

“As a result of today’s decision, a Florida jury’s verdict … will be drastically reduced to a fraction of what the jury determined that the circumstances of the case warrant,” Labarga wrote. “This drastic reduction is attributable to the majority’s analysis of the rephrased certified question, an analysis that unreasonably concludes that the decedent’s death is not a cognizable injury for purposes of punitive damages claim.”

Labarga argued that relying on the quirks of the state’s wrongful-death statute, which has its roots in 1840s case law in England and does not consider a death to be an injury for the purposes of allowing damages to survivors, was a “strained interpretation.”

“The majority’s interpretation raises the question: when evaluating punitive damages in a wrongful death case, how can a decedent’s death not be a cognizable injury,” Labarga wrote. “The Wrongful Death Act, with its focus on compensatory damages, should not be read to limit the type of injury cognizable in determining punitive damages.”

Higher punitive damages are needed to hold R.J. Reynolds fully accountable, he added. The majority’s interpretation puts Florida courts in the position of supporting higher damages for injuries than for deaths.

A Florida law professor, not known for agreeing with Florida’s conservative high court, said in this case Labarga is wrong.

Jarvis

“Although I am usually quite critical of the Florida Supreme Court, this time it is right,” said Robert Jarvis, who teaches constitutional law at Nova Southeastern University in Fort Lauderdale. “LaBarga wants to introduce a distinction into Florida’s wrongful death statute (between compensatory and punitive damages) that simply does not exist – but would be very helpful for litigants like Coates if it did.”

State lawmakers could remedy the oddity by amending the wrongful-death statute to include a death as a measure of damage, he noted.

Jarvis disagreed with the sentiment that the Supreme Court can now be considered a “textualist” court, given to strict reading of the Legislature’s language and intentions in drafting laws in all matters. He noted that the court in other cases has found ways to work around statutory or constitutional language. The justices, for example, allowed the recent nomination of Justice Renatha Francis to be delayed so that she could meet the Florida Constitution’s 10-year Bar membership requirement.

“What this court is, instead, is a hard-right/pro-business court,” Jarvis said in an email. “In Coates, textualism gave the court the decision it wanted. Had textualism not done so, however, I believe the court would have found another reason to vote the way it did.”

The Coates decision is not directly related to property and liability insurance. The R.J. Reynolds corporation is largely self-insured, and punitive damages generally are not covered by liability insurance policies, anyway. But the ruling could have an impact on insurers in that it could reduce the threat of excessive punitive damage awards and, perhaps, extra litigation in some pending and future cases. Concerns about large verdicts have in often incentivized insurers to press for settlements in litigation, putting them at odds with insured business owners who may want to go to trial, Large and other attorneys have said.

The decision could also prompt defendant corporations to ask courts more often for what’s known as “remittitur,” or a reduction in punitive damages.

Strict interpretation of the text of statutes and insurance policies has been a factor in a number of significant court rulings in recent years — ones that were mostly in favor of insurers.

In June, Florida’s 4th District Court of Appeal found that a contractor in an assignment-of-benefits claim did not provide an itemized, per-unit cost estimate of the services to be performed in the restoration, as required by law. In late 2021, the same court found that policy requirements must be adhered to: A homeowners policy limited payouts on emergency mediation work to $3,000, unless a request was made to exceed that.

Also in 2021, the 3rd District Court of Appeal sided against an AOB contractor and held that an HO policy required the signature of both spouses and the mortgage lender.

https://www.insurancejournal.com/news/southeast/2023/01/08/702390.htm

Auto Insurance increases Florida’s cost of living

January 4, 2023/in The Miami Times

Mitch Perry Florida Phoenix Jan 4, 2023 Updated Jan 4, 2023

While the average American motorist spends 2.57% of their annual income on autoinsurance,
Florida drivers spend the second-highest proportion at 4.42%, trailingonly Louisiana, at 5.26%.
Of all the metro areas analyzed, Miami drivers spendthe absolute highest, at 5.58%.(Envato Elements)

Florida lawmakers returned to Tallahassee before Christmas for another special session to deal with the state’s property insurance crisis. But it’s not just homes and condos where Floridians pay high insurance rates – they’re also forking over large amounts for automobile insurance. In fact, Florida’s auto insurance rates are among the highest in the nation.

An analysis from Insure.com ranks Florida as the most expensive state in the nation for auto insurance, with the average premium at $2,560 a year. That’s a whopping 23% increase in rates from 2021. The average nationwide for full coverage car insurance is currently $1,682.

Another study, Bankrate’s True Cost of Auto Insurance Report in 2022, showed that the average annual full coverage car insurance premium for a Floridian is even higher at $2,762, the second-highest rate in the country.

A DeSantis veto

A majority of state lawmakers believed that they had addressed the issue to some extent in 2021, when they passed a bill (SB 54) co-sponsored by Tampa Bay-area state Sens. Danny Burgess (R- Zephyrhills) and Darryl Rouson (D-St. Petersburg) that would have repealed the state’s “no fault” insurance law that requires that motorists carry $10,000 in personal-injury protection (PIP) coverage.

It would have replaced PIP with mandatory bodily injury (BI) coverage of at least $25,000 per person and $50,000 per occurrence, and required insurers to offer medical payments coverage (though policy holders could opt out of that coverage).

Gov. Ron DeSantis vetoed the bill, saying that the measure did “not adequately address the current issues facing Florida drivers.”

It definitely would have raised car insurance rates, according to a report commissioned by the Office of Insurance Regulation published right before that veto.

The study from Pinnacle Actuarial Resources determined that if “no fault” was repealed, motorists would have seen their insurance premiums increase by 13%, or approximately $202 per vehicle annually. And the liability premium would go up nearly 20% for motorists who purchased medical payment coverage with a $10,000 limit.

Some think motorists would have been better off if the legislation had passed.

“When I see people move to Florida who come from other states that have mandatory bodily injury liability, their premiums always seem to be lower,” said Brandon-based insurance agent Kevin Swanson, who says he hasn’t read enough studies to have a firm opinion on the issue.

“PIP is riddled with fraud. It is a problem,” said Michael Carlson, president and CEO of the Personal Insurance Federation of Florida (PIFF). “We have state law enforcement constantly working to root it out.”

That fraud plays itself by in several ways, Carlson says, such as a “whole cottage industry of phony medical providers” that send fraudulent medical bills to auto insurance companies.

There are also incidents with motorists staging accidents, and Tampa and Miami are known as being among the top cities in the country where such fraud is prevalent.

Rampant fraud

In July, Florida’s chief financial officer, Jimmy Patronis, announced the arrest of Angela Ippolito Duncan, owner of the Ybor Medical Center, for allegedly planning and participating in staged car accidents to submit more than $970,000 in fake accident automobile insurance claims.

“Scam artists are working every day to drive up your insurance rates to line their own pockets,” Patronis said after the arrest was made.

Another factor driving up rates is glass replacement fraud, which observers say has gone unchecked for years. This is where contractors will go after motorists in parking lots, gas stations or knock on their front doors to inform them they can have their windshields replaced for no cost if they have comprehensive insurance coverage, which about 90% of Florida drivers do, according to Mark Friedlander with the Insurance Information Institute.

What motorists don’t realize, however, is that once they sign the paperwork with those contractors to get their windshield replaced, they have “assigned” a law firm to handle the issue with their insurance company. That has led to an explosion of lawsuits filed in Florida over the past decade by more than 4,000%, according to a consortium of organizations calling themselves “Fix the Cracks.”

“This is an area of law where these cases were virtually nonexistent 10 years ago and now they’ve perforated into the thousands, and the only explanation is that there was either a massive meteorite shower that went over the state of Florida, or the incentive for attorneys’ fees is driving this …” said William Large, the president of the Florida Justice Reform Institute.

The Bankrate report also states that Florida drivers spend the second-highest proportion of their money on car insurance at 4.42% of their income, trailing only Louisiana at 5.26%. And of all the metro areas in the nation analyzed, Miami and Tampa drivers spend the highest percentage of their annual income on car insurance coverage, at 5.58% and 4.49%, respectively. The average American motorist spends 2.57% of their annual income on auto insurance.

Climate & inflation

Another factor in Florida’s high auto insurance rates are frequent storms and flooding, and the fact that the state simply sees a lot of auto accidents.

There were 3,737 fatalities from car crashes last year, making Florida the third-most dangerous state to drive in the country, according to the National Highway Traffic Safety Administration. There were more than 400,000 automobile crashes in Florida in 2021, resulting in more than 252,000 injuries.

Also, 1 in every 5 drivers (20.4%) in the state is uninsured, the sixth-highest rate in the nation.

While the issues in Florida contribute to higher-than-average premiums, national and global issues play a part as well, such as inflation and the breakdown in the supply chain that has raised rates everywhere.

“When an insurance company has to make you right after a crash, they (now) have a bigger payout. And if they have a bigger payout, they have to recover that somewhere,” said Michael Giusti, a senior reporter and analyst for InsuranceQuotes.com.

Whether the Legislature is poised to take up any of these issues next year isn’t certain, but observers note that after the DeSantis veto, the appetite for auto insurance reform in Tallahassee chilled considerably.

So will the Legislature attempt auto insurance reform in 2023?

“I don’t think so,” Large said. “I think that the advocates who are moving for a bill to go from PIP to BI probably got a very clear message from Gov. DeSantis vis a vis his veto, and I don’t think they’re going to try to bring up a bill up in 2023.”

But the future isn’t all bad news for Floridians hoping to save on auto insurance bills. Unlike property insurers, who are dissolving and abandoning Florida at an alarming rate, the auto insurance industry remains robust in Florida, with more than 50 companies writing policies for motorists.

“If you look at all the insurance products around the country, auto insurance is the most competitive,” said Friedlander. “Rates vary significantly between companies. And we always recommend (that you) shop your coverage if your rates are going up, because you can get multiple quotes and different discount programs that will help you.”

https://www.miamitimesonline.com/business/auto-insurance-increases-floridas-cost-of-living/article_1eac9488-8c42-11ed-8edb-1ff5b5fad2e0.html

FLORIDA RECORD

Florida Justice Reform Institute President William Large agreed with the appeals court decision. | Florida Justice Reform Institute

(l-r) Third DCA Chief Judge Ivan F. Fernandez, and Judges Bronwyn C. Miller and Alexander S. Bokor (Courtesy photos)

William Large, President of the Florida Justice Reform Institute

The Third District Court of Appeal

FLORIDA RECORD

Friday, January 13, 2023

Florida Justice Reform Institute President William Large called the state Supreme Court ruling a victory for textualism. | Florida Justice Reform Institute

William Large and the FJRI earned a major win this week. Image via Colin Hackley.

By William Rabb | January 8, 2023

Mitch Perry Florida Phoenix Jan 4, 2023 Updated Jan 4, 2023

While the average American motorist spends 2.57% of their annual income on autoinsurance, Florida drivers spend the second-highest proportion at 4.42%, trailingonly Louisiana, at 5.26%. Of all the metro areas analyzed, Miami drivers spendthe absolute highest, at 5.58%.(Envato Elements)

Florida Justice Reform Institute

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William Large and the FJRI earned a major win this week.
Image via Colin Hackley.

While the average American motorist spends 2.57% of their annual income on autoinsurance,
Florida drivers spend the second-highest proportion at 4.42%, trailingonly Louisiana, at 5.26%.
Of all the metro areas analyzed, Miami drivers spendthe absolute highest, at 5.58%.(Envato Elements)