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Third DCA Holds Plaintiff Cannot Recover PIP Benefits for Treatment Rendered by a Licensed Massage Therapist

Congratulations to Caryn Bellus and Angela Flowers for a great appellate PIP win!

In Geico Gen. Ins. Co. v. Finlay Diagnostic Center, Inc., 2021 WL 1652041 (Fla. 3d DCA, April 28, 2021), the Third District Court of Appeal reversed a trial court order granting Plaintiff PIP benefits for medical treatments rendered by a licensed massage therapist (“LMT”), confirming that such treatment is not recoverable under §627. 736(1)(a)(5), Fla. Stat.

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