Dodgen v. Grijalva
In an auto negligence case, the plaintiff sought discovery of the financial relationship between the defendant's nonparty liability insurer and the defense's retained expert witnesses. The Florida Supreme Court, reframing the Fourth District's certified question, held that permitting such discovery is not a departure from the essential requirements of law because Worley v. Central Florida YMCA addressed only plaintiff-side treating physicians and law firm referral relationships, and does not apply to defense-retained experts. The Court approved Springer v. West and declined to revisit Worley in a case where it was inapplicable.
Key facts
- Plaintiff Dodgen sought discovery of financial relationships between defendant Grijalva's liability insurer and defense-retained expert witnesses in an auto negligence case.
- The trial court granted Dodgen's discovery request; Grijalva petitioned for certiorari relief, arguing the Worley decision prohibited such discovery.
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Why it matters
This decision (companion to Younkin v. Blackwelder) settles a heavily litigated post-Worley dispute: defendants cannot invoke Worley to shield insurer-expert financial relationships from discovery, leaving the asymmetry… — full analysis with a trial
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