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 experts. The Florida Supreme Court reframed the Fourth District's certified question and held it is not a departure from the essential requirements of law to permit such discovery, because Worley v. Central Florida YMCA addressed only the plaintiff side (attorney-client privilege and referral relationships with treating physicians) and does not establish clearly established law on the defense side. The Court approved the Fourth District's denial of certiorari and expressly declined to revisit Worley, endorsing the Fifth District's Springer v. West rule.
Key facts
- Plaintiff sought discovery of the financial relationship between defendant's nonparty liability insurer and the defense's retained experts in an auto negligence case.
- The Fourth District Court of Appeal denied certiorari relief from the trial court's order compelling such discovery.
- +2 more key facts with a free trial
Why it matters
This is the companion case to Younkin v. Blackwelder and settles a heavily litigated post-Worley discovery battleground: defense-side experts' financial ties to the insured's nonparty carrier remain fully discoverable… — full analysis with a trial
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