Younkin v. Blackwelder
In an auto negligence case, the plaintiff sought discovery of the financial relationship between the defense's nonparty law firm and the defense's retained medical expert. The Florida Supreme Court, applying its companion decision in Dodgen v. Grijalva, distinguished Worley v. Central Florida YMCA (which barred discovery of attorney referrals of plaintiffs to treating physicians as attorney-client privileged) and answered the reframed certified question in the negative: permitting such discovery is not a departure from the essential requirements of law. The Court declined the dissent's invitation to recede from Worley, reasoning that doing so would be advisory because it would not change the discovery ruling under review.
Key facts
- Plaintiff sought discovery of the financial relationship between the defense's nonparty law firm and the defense's retained medical expert in an auto negligence case.
- The trial court permitted discovery of the defense law firm/expert financial relationship.
- +2 more key facts with a free trial
Why it matters
This decision, companion to Dodgen v. Grijalva, definitively confirms the asymmetry in Florida expert-bias discovery: defense law firm/insurer-expert financial relationships remain fully discoverable while Worley… — full analysis with a trial
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