Geico Casualty Co. v. MSP Recovery Claims
GEICO sought prohibition and certiorari from an order denying its motions to dismiss MSP's second amended complaint (a declaratory count and a pure bill of discovery) and for a protective order. The Third DCA denied prohibition, holding that because the circuit court indisputably had subject matter jurisdiction over the pure bill of discovery count, it could also entertain the declaratory count even if that count alone fell below the jurisdictional threshold. It dismissed the certiorari petition because an order denying a protective order aimed at the entirety of the information sought by a pure bill of discovery — with no pending discovery request and no order compelling production — causes no irreparable harm.
Key facts
- GEICO sought prohibition and certiorari from a circuit court order denying its motions to dismiss MSP's second amended complaint, which included a declaratory count based on PIP coverage and a pure bill of discovery count.
- MSP Recovery Claims alleged that GEICO was obligated to reimburse it for personal injury protection benefits it had paid to claimants.
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Why it matters
The opinion extends American Medical Systems, LLC v. MSP Recovery Claims to orders denying protective orders in pure bill of discovery actions, sharply limiting insurers' and defendants' ability to obtain interlocutory… — full analysis with a trial
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