State Farm Mut. Auto. Ins. Co. v. Nichols

Summary

The Supreme Court of Florida held that an action to recover personal injury protection benefits is a civil action for damages subject to Florida's offer of judgment statute. It further held that the offer of judgment statute does not conflict with the PIP statute's one-way attorney's-fee provision and does not violate constitutional access-to-courts protections. However, the insurer's settlement proposal was too ambiguous regarding the scope of a general release to satisfy Florida Rule of Civil Procedure 1.442, so the attorney's-fee award was reversed.

Holdings

1. A suit for PIP benefits is a civil action for damages subject to Florida's offer-of-judgment statute, section 768.79.
2. The PIP statute's provision authorizing attorney's fees for prevailing insureds does not preclude an insurer from recovering post-offer fees under section 768.79 when the statutory conditions are met.
3. Applying the offer-of-judgment statute to PIP suits does not violate article I, section 21 of the Florida Constitution or render the PIP statutory scheme unconstitutional.
4. A general release is a relevant condition or nonmonetary term that must be stated with particularity under Florida Rule of Civil Procedure 1.442.
5. State Farm's proposal was invalid under Rule 1.442 because its broad general-release language could reasonably be construed to extinguish Nichols's separate uninsured-motorist claim.

Questions Presented

1. Whether a suit by an insured to recover personal injury protection benefits is a civil action for damages subject to Florida's offer-of-judgment statute.
2. Whether the PIP statute's provision authorizing attorney's fees for prevailing insureds precludes an insurer from recovering fees under the offer-of-judgment statute.
3. Whether applying the offer-of-judgment statute to PIP suits violates the Florida Constitution's access-to-courts guarantee.
4. Whether State Farm's settlement proposal, requiring Nichols to execute a general release, satisfied Florida Rule of Civil Procedure 1.442's particularity requirements.

Disposition

approved