United Automobile Insurance Company v. Chiropractic Clinics of South Florida, PL a/a/o Michael Akins
United Auto wrongly denied PIP coverage after a faulty database search confused the insured's mother with a different person; relying on that denial, the insured told his chiropractor he had no PIP coverage and the provider billed late. The Third DCA affirmed summary judgment for the provider, holding United Auto was equitably estopped from asserting the 35-day billing deadline in section 627.736(5)(c) because the late billing flowed directly from the insurer's own erroneous coverage denial.
Key facts
- United Auto issued a PIP insurance policy to Michael Akins; the insurer wrongly denied PIP coverage after a faulty database search confused Akins's mother with a different person.
- Relying on United Auto's erroneous denial, Akins told his chiropractor (Chiropractic Clinics of South Florida) he had no PIP coverage, and the provider submitted its billing claim after the 35-day statutory deadline.
- +2 more key facts with a free trial
Why it matters
This gives PIP providers and assignees a concrete estoppel answer to the common 35-day late-billing affirmative defense where the insurer's own wrongful coverage denial caused the delay, and it confirms that the… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.