– Summary by Anna Lusk
On May 26, 2022, the Supreme Court of Florida considered whether it had jurisdiction over a case concerning workers’ compensation reimbursement. The Supreme Court concluded that jurisdiction for cases like these are not exclusive to the Department of Financial Services, and that the Supreme Court, and lower courts, may decide on cases like the one at hand.
Ms. Patty Davis was injured during the course of her employment. She utilized workers’ compensation benefits to receive medical care for her work-related injuries. Ms. Davis received medical care from two providers who repeatedly billed her directly for the medical care she received. Ms. Davis then filed suit against both medical providers. She argued that under the Workers’ Compensation Law (WCL), she was not supposed to be billed for having sought medical care for her work-related injuries. She argued instead that her compensation carrier should be responsible for reimbursing the medical care providers. Ms. Davis argued that the medical providers’ attempts to collect the debt from her constituted an attempt to collect illegitimate debt, which violates the Florida Consumer Collection Practices Act (FCCPA). The medical providers asserted that the trial courts lacked jurisdiction because the Workers’ Compensation Law states that the Department of Financial Services (DFS) “has exclusive jurisdiction to decide any matters concerning reimbursement.” Because this case is concerned with reimbursement, the medical providers argued that only the DFS may decide on this case. The trial courts agreed with the medical providers and dismissed this case. Ms. Davis appealed to the Second District Court of Appeal, which held that the trial courts erred in dismissing her case, and that the Supreme Court of Florida must decide whether the courts have jurisdiction for cases like Ms. Davis’s.
In its analysis, the Supreme Court focused heavily on the statutory language of the FCCPA and the WCL. The Supreme Court determined that to answer the question the lower courts provided, the Court must determine the scope of the provision on “exclusive jurisdiction” of section 440.13(11)(c) of the WCL. More specifically, the Court considered the meaning of the phrase “exclusive jurisdiction to decide any matters concerning reimbursement” to determine if the courts may review questions of reimbursement of workers. The Court considered this phrase in two parts: the meaning of “reimbursement”; and the effect of the words “matters concerning reimbursement” on “exclusive jurisdiction.” The Court found that the dictionary meaning, the ordinary meaning, and the meaning of the word “reimbursement” as used throughout the WCL does not apply to the case at hand. The Court then found that the words “matters concerning reimbursement” pertain to payments by a carrier to a provider, and so does not apply to this case. The Court concluded that the matter at issue here is not a “matter concerning reimbursement” subject to the jurisdiction of DFS. Therefore, the jurisdiction of the courts is not affected by this provision. The Court does have jurisdiction over this case, and this case is not an issue of reimbursement under the WCL.