In Williams v. Nono, 333 So. 3d 1128 (Fla. 5th DCA 2022), Angela Flowers, of our Ocala office, received a decision in an auto liability case affirming the application of both sections 627.736(3) and 768.76(1), Fla. Stats., to reduce the gross verdict. Both statutes support the reduction of a verdict post-trial by setting off all Personal Injury Protection (“PIP”) payments made as well as for any balance billing that occurred that is not owed pursuant to the terms of any contractual/policy language. At trial, the jury received an agreed-upon medical bill summary reflecting the total unreduced charges for past medical treatments and made a partial award. Angela successfully argued that the two collateral source statutes operate in tandem to prevent an impermissible windfall by way of double recovery. The setoff resulted in a net judgment in favor of the defendant, who was entitled to attorney’s fees based on a successful proposal for settlement.