State Farm Mutual Automobile Insurance v. Dixon

State Farm Mutual Automobile Insurance Company (“State Farm”) appeals from a Final Judgment, entered upon a jury verdict, awarding John and Dorothy Dixon (“the Dixons”) uninsured motorist benefits, including non-economic damages. State Farm argues that it was reversible error to allow an award for non-economic damages where the insured did not first meet the threshold requirements of section 627.737(2)(a-d), Florida Statutes.

The Dixons collided with a vehicle driven by an uninsured motorist and sought benefits from State Farm, their uninsured motorist carrier. State Farm did not pay benefits…