Michael Clarke and Joye Walford of our Tampa office, obtained an opinion reversing a summary judgment for a provider/assignee in a PIP action and remanding with directions to enter final judgment for the insurer. See Progressive Specialty Ins. Co. v. Fla. Hosp. Ocala, Inc., No. 6D2023-1347 (Fla. 6th DCA Oct. 14, 2024). The issue on appeal was whether a Maryland policy’s out-of-state coverage clause applied to increase the policy’s $2,500 PIP limit to conform to Florida’s $10,000 PIP requirement. The case largely hinged on the interpretation of the policy’s out-of-state coverage provision’s language limiting its application to states “requiring a non-resident to maintain insurance whenever the non-resident uses an auto in that state.” The Sixth District Court of Appeal held that Florida did not require a non-resident to maintain insurance whenever he or she uses a car in Florida because there are instances in which a non-resident could use a car in Florida without triggering compulsory insurance coverage. The Court contrasted this language with an out of-state coverage provision that applies “If an insured is in another state … and, as a non-resident, becomes subject to its” compulsory insurance laws, which the Court concluded could trigger application of Florida’s PIP requirement. This is yet another example of the importance that every single word of a policy’s provision counts and should be carefully analyzed when determining whether it applies under the facts of the case. View the opinion here.