MGA Insurance Company, Inc., etc. v. MSP Recovery Claims, Series LLC, etc., et al.
The Third District consolidated three interlocutory appeals from non-resident insurers USAA, MGA, and Progressive, each sued by MSP Recovery entities for pure bills of discovery and declaratory relief under Florida's PIP statute. The court reversed the trial court's orders denying motions to dismiss, holding that the complaints failed to allege sufficient ultimate facts to establish either general or specific personal jurisdiction under Florida's long-arm statute, and that the insurers did not waive their jurisdictional defenses.
Key facts
- MSP Recovery entities filed pure bills of discovery and declaratory relief actions against USAA, MGA, and Progressive in Miami-Dade circuit court, alleging the insurers failed to coordinate benefits with Medicare and Medicaid managed care organizations and their assignees as required by federal law and Florida's PIP statute.
- All three cases were paused for approximately two years while MSP Recovery unsuccessfully sought to disqualify the insurers' shared counsel, Akerman LLP, delaying substantive litigation until after the Florida Supreme Court denied further review.
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Holdings
- Florida courts require a complaint to allege sufficient ultimate facts establishing either general or specific personal jurisdiction under Florida's long-arm statute (§ 48.193, Fla. Stat.)…
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