Rodriguez v. Government Employees Insurance

I would not grant the petition for second-tier review. The Florida Supreme Court in Custer Med. Ctr. v. United Auto. Ins. Co., 62 So.3d 1086 (Fla.2010), and more recently this Court in United Auto. Ins. Co. v. Palm Chiropractic Ctr., Inc., 51 So.3d 506, 508 (Fla. 4th DCA 2010), have made it abundantly clear that judicial review “ ‘should consistently become narrow*1046er, not broader’ ” as a case travels up the judicial ladder. Custer Med. Ctr., 62 So.3d at 1092 (quoting Haines City Cmty. Dev. v. Heggs, 658 So.2d 523, 530 (Fla.1995)). “Therefore, when a district court considers a petition for…