In United Automobile Insurance Company v. ISO-Diagnostics Testing, Inc., No. 4D2022-1735 (Fla. 4th DCA Jan. 10. 2024), the Fourth District Court of Appeal held that the term “year” as it appears in Florida’s No-Fault Statute, section 627.736, refers to a service year and not a calendar year. Importantly, while the Florida Legislature made this clear in its 2015 amendment to section 627.736(5)(a)2, replacing the term “year” with “service year” and defining it as “the period from March 1 through the end of February of the following year,” the Fourth District explained that even prior to the Legislature’s 2015 amendment, the Legislature intended the word “year” to mean a service year beginning on March 1. The Fourth District reasoned that although the Legislature had not previously used the term “service year” or defined that term in the Statute, it still referred to the March 1 date, supporting the plain meaning to be that a service year—not a calendar year—applied. View full opinion here.