Progressive American Insurance Co. v. Eduardo J. Garrido D.C. P.A., Etc.

Appellant, defendant below, Progressive American Insurance Company (“Progressive”), appeals a final summary judgment of the Miami-Dade County Court that both (i) declared a portion of Florida’s PIP statute unconstitutional as applied to chiropractors; and (ii) determined that, in the absence of an “emergency medical condition” diagnosis, Florida’s PIP statute allows an insured to recover up to $10,000 in PIP benefits. The county court certified the constitutional issue to us as a question of great public importance. We accepted jurisdiction, 1 and we reverse the county court’s final summary…