USAA Casualty Insurance Company v. MSP Recovery Claims, Series LLC

CourtDistrict Court of Appeal of Florida
DecidedDecember 17, 2025
Docket3D2024-1056
StatusPublished

This text of USAA Casualty Insurance Company v. MSP Recovery Claims, Series LLC (USAA Casualty Insurance Company v. MSP Recovery Claims, Series LLC) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USAA Casualty Insurance Company v. MSP Recovery Claims, Series LLC, (Fla. Ct. App. 2025).

Opinion

Third District Court of Appeal State of Florida Opinion filed December 17, 2025. Not final until disposition of timely filed motion for rehearing.

________________

Nos. 3D24-1056, 3D24-1316, 3D24-1278 Lower Tribunal Nos. 18-42110-CA-01, 1842205-CA-01, 18-42463- CA-01 ________________

USAA Casualty Insurance Company, et al., Progressive Advanced Insurance Company, et al., and MGA Insurance Company, Inc., etc., Appellants,

vs.

MSP Recovery Claims, Series LLC, etc., et al., Appellees.

Appeals from the Circuit Court for Miami-Dade County, David C. Miller, Judge.

Akerman LLP, Alexander J. Hall, Valerie B. Greenberg, and Nancy A. Copperthwaite, for appellants.

MSP Recovery Law Firm and Ryan H. Susman, for appellees.

Before EMAS, FERNANDEZ and LINDSEY, JJ. FERNANDEZ, J.

In case numbers 3D24-1056, 3D24-1278, and 3D24-1316,

defendants/appellants USAA Casualty Insurance Company and USAA

General Indemnity Company (“USAA”); MGA Insurance Company; and

Progressive Advanced Insurance Company, et al. (“Progressive”),

respectively, appeal the trial court’s orders in each of their appeals denying

their motions to dismiss for lack of personal jurisdiction. Plaintiffs/appellees

MSP Recovery Claims, Series LLC (“MSP Recovery”); MSPA Claims 1, LLC

(“MSPA Claims”); MSP Recovery Claims Series 44, LLC; and Series PMPI

(all three referred to collectively as “plaintiffs”) are represented by the same

counsel in these cases. USAA, MGA, and Progressive, et al. are represented

by the same counsel before this Court and in the trial court.

The three appeals arise from circuit court actions filed by plaintiffs for

pure bills of discovery under the Florida Motor Vehicle No-Fault (“PIP”)

Statute, section 627.376, Florida Statutes (2018). The subject complaints in

each case make the same allegations regarding personal jurisdiction. In

each case, the trial court denied the insurance companies’ motions to

dismiss based on personal jurisdiction. Each motion to dismiss relied on

Florida and federal caselaw finding no personal jurisdiction in similar cases

filed by plaintiffs. Accordingly, because the three related appeals raise the

2 same legal issue, we now consolidate them for purposes of this opinion. For

the following reasons, we reverse and remand with instructions to dismiss

each case for lack of personal jurisdiction.

Facts Related to the Three Underlying Cases

In each of plaintiffs’ complaints, plaintiffs sought information about

unspecified insureds who were involved in auto accidents and who also had

Medicaid coverage. Plaintiffs filed the lawsuits after assignments were

allegedly obtained from managed care organizations and related entities.

No merits discovery took place while plaintiffs were trying to disqualify

the insurance companies’ counsel. Plaintiffs started to prosecute the three

underlying lawsuits after this Court rejected their disqualifications motions

and after the Florida Supreme Court denied plaintiffs further review.

When the merits litigation resumed, plaintiffs amended their

complaints, increased the number of assignors, and added claims involving

Medicare beneficiaries in addition to Medicaid beneficiaries. They also

sought relief as a class action. Plaintiffs now seek declarations that contrary

to federal requirements, the Insurers “must coordinate benefits with

Secondary Payors”; the Insurers must “alert Secondary Payors of their

primary obligations”; that contrary to Florida law, Secondary Payors “are not

3 obligated to submit a demand for reimbursement on a properly completed .

. . standard form”; and Secondary Payors need not “comply with the strict

requirements” of the PIP Statute. 1

The three insurers moved to dismiss the new complaints on various

grounds, including lack of personal jurisdiction. The insurers argued that

plaintiffs failed to allege sufficient ultimate facts to establish either general or

specific jurisdiction over them. In support of their motions to dismiss, the

insurers cited to MSP Recovery Claims, Series LLC v. Coloplast

Corporation, 353 So. 3d 705 (Fla. 3d DCA 2023) (“Coloplast I”); MSP

Recovery Claims Series v. Nationwide Mut. Ins. Co., 2021 WL 355133 (S.D.

Fla. Feb. 2, 2021) (granting motion to dismiss for lack of personal

jurisdiction); and MSP Recovery Claims, Series LLC v. 21st Century

Centennial Ins. Co., 2023 WL 11903567 (Fla. 11th Cir. Jan. 25, 2023)

(same). In Coloplast I, this Court affirmed the trial court’s dismissal for lack

of personal jurisdiction and rejected plaintiffs’ argument to extend long-arm

1 Plaintiffs define “Secondary Payors” as “all nongovernmental organizations, including but not limited to Medicaid Managed Care Organizations [‘MCOs’], Medicare Advantage Organizations [‘MAOs’], first-tier and downstream entities and their assignees, that provide health and prescription benefits in the State of Florida.” The Assignors allegedly are Secondary Payors.

4 jurisdiction for a pure bill of discovery in the manufacturing context. Coloplast

I, 353 So. 3d at 706-07.2

The USAA appeal – 3D24-1056

Plaintiffs filed the underlying action for a pure bill of discovery regarding

PIP claims then amended their pleading and added a second count for

declaratory relief. USAA moved to dismiss both complaints. There was no

hearing or ruling on either motion.

The proceedings were paused from 2020-2023 while plaintiffs sought

to disqualify USAA’s counsel, which was not successful. Akerman LLP v.

MSP Recovery Claims, Series LLC, 338 So. 3d 309 (Fla. 3d DCA 2022), rev.

denied, 2022 WL 4930534 (Fla. Oct. 4, 2022).

After the action resumed in the trial court, plaintiffs amended their

complaint again. USAA moved to dismiss the second amended complaint on

various grounds, including that the complaint had insufficient allegations as

to personal jurisdiction. The trial court at first denied USAA’s motion to

2 Later, in Coloplast Corporation v. MSP Recovery Claims, Series, LLC, 415 So. 3d 353, 353 (Fla. 3d DCA 2025) (“Coloplast II”), this Court reversed the trial court’s denial of Coloplast’s second motion to dismiss. This Court rejected MSP’s position that it had established jurisdiction for a pure bill of discovery against a foreign medical device manufacturer, including under the business-venture prong of Florida’s long-arm statute. § 48.193(1)(a)(1), Fla. Stat. (2023).

5 dismiss “in all respects except on the grounds asserting lack of personal

jurisdiction.” The trial court reserved ruling on the jurisdictional issue until the

evidentiary class certification hearing on May 17, 2024.

At the evidentiary class certification hearing, the trial court rejected

USAA’s jurisdictional argument. Because the trial court required USAA to

participate in a class certification hearing before ruling on its jurisdictional

defense, at the court’s suggestion, plaintiffs stipulated that USAA’s “actions

in engaging in discovery to defend against the motion for class certification

would not constitute a waiver of Defendants’ argument that the Court lacks

personal jurisdiction over them.” However, the trial court ruled that USAA

waived its personal jurisdiction defense by not raising it earlier. The trial court

granted the motion for certification.

USAA appealed the dismissal order (and the certification order) to this

Court. See Third District Court of Appeal Case No. 3D24-1116, USAA

Casualty Insurance Co.

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