Carolina Bolado
December 26, 2025
Judge Orders State Farm To Restart Paying PIP Claims To Co.
4 min
AI-made summary
- A Florida state judge ordered State Farm to resume processing and paying personal injury protection (PIP) claims from Complete Care Centers LLC, after finding the insurer improperly blocked the provider from filing claims without court approval
- The judge required State Farm to assign three employees to handle Complete Care’s PIP claims, stop sending breach letters to policyholders, and notify affected patients of the retraction
- Complete Care must post a $25,000 bond while litigation continues.
A Florida state judge has ordered State Farm to pay out benefits for its insureds to an automobile-crash-focused healthcare company, ruling that the insurer cannot unilaterally stop paying all of its policyholders' crash medical benefits to a provider unless it convinces a court that the provider is ineligible.
In a strongly worded opinion issued Tuesday, Thirteenth Judicial Circuit Judge Paul L. Huey ordered State Farm to process personal injury protection claims from Complete Care Centers LLC and to assign three employees to handle all PIP claims from Complete Care while the litigation is pending.
The judge pointed to an admission from State Farm that the insurer on April 3, 2025, essentially blocked Complete Care from filing any PIP claims for services rendered to State Farm's insureds, essentially getting a self-imposed injunction without satisfying any of the legal requirements.
This is costing Complete Care more than $600,000 each month and is crippling Complete Care's business, according to the order.
"State Farm obviously acted deliberately in the hope that it could convince a judge like me that the only power I have is to maintain the status quo, which is to protect State Farm's self-imposed mandatory injunction," Judge Huey said. "That is simply wrong, and this court will not join in such folly."
State Farm argued that it was justified in its decision to stop processing PIP claims from Complete Care because the provider delayed collecting deductibles and co-insurance payments from patients. But Judge Huey said Complete Care CEO Brent Williams testified that the providers collects 86% of all copayments and deductibles, a rate that even State Farm's corporate representative said was very good.
The judge said that the term "delay" is not in Florida's PIP statute, and that he could not get a straight answer from the insurer's corporate representative about what exactly would constitute an illegal delay.
"I asked him to look straight at Mr. Williams, Complete Care CEO, and tell him what he would have to do to get State Farm to, in essence, lift its injunction and start paying Complete Care," Judge Huey said. "Again, no concrete answer."
The judge said State Farm has sent breach letters to policyholders advising them that the insurer would not abide by its contract with them to pay claims because it has sued Complete Care to determine whether it needs to pay the claims. The breach letters insinuate that the policyholder does not have to pay copayments and deductibles until a court determines that the bill is legally compensable, according to the order.
"State Farm is demanding with its right hand in repeated litigation that Complete Care must collect copays and deductibles ASAP from its patients while, at the same time, its left hand is telling patients not to pay those charges," Judge Huey said.
The judge added that even if Complete Care failed to collect copayments and deductibles from policyholders, it cannot damage State Farm because the insurer is not responsible for those payments regardless. But Complete Care's brand and standing with urgent care centers, hospitals, primary care physicians and attorneys who have previously referred patients is being significantly damaged, according to the order.
The judge ordered Complete Care to post a bond of $25,000 "to cover even the slightest possibility that State Farm could be damaged." State Farm must immediately stop sending breach letters and has 20 days to send a letter to every Complete Care patient who received a breach letter advising that the insurer has retracted all prior letters, according to the order.
State Farm must also process PIP claims submitted by Complete Care since April 1 and has to assign three employees to handle all Complete Care PIP claims during the litigation so that in the event there are accusations that State Farm is violating the injunction, the court will know who needs to be deposed to find out what is happening, according to the order.
"This is about protecting Florida drivers' access to care after an accident, and most importantly it protects patients' rights to visit the doctor of their choice following an accident," Jason Goldman of Davis Goldman PLLC, who represents Complete Care, said in a statement. "The court made clear that insurers like State Farm cannot act as the accuser, judge, jury and executioner by unilaterally refusing to process and pay all claims for PIP benefits submitted by a particular medical provider."
Attorneys for State Farm did not immediately respond to a request for comment.
Complete Care is represented by John D. Goldsmith and Patrick M. Causey of Trenam Law, and Jason N. Goldman of Davis Goldman PLLC.
State Farm is represented by David I. Spector and James J. Duffy of Holland & Knight LLP and Jordanne A. Spencer of Cole Scott & Kissane PA.
The case is Complete Care Centers LLC v. State Farm Mutual Automobile Insurance Co. et al., case number 25-CA-001063, in the Thirteenth Judicial Circuit Court of Florida.
Article Author
Carolina Bolado
The Sponsor
