A Practitioner’s Guide to Critical Differences Between These Jurisdictions
Introduction
Georgia and Florida present a compelling comparison following Florida’s seismic tort reform in March 2023. For decades, Florida operated as a pure comparative negligence state with a 4-year statute of limitations; now it mirrors Georgia’s modified comparative framework with a 2-year limitations period. Yet critical differences remain. Florida’s no-fault auto insurance system, restrictive dram shop law, and medical malpractice carve-out maintaining pure comparative negligence create distinct strategic considerations. Understanding both the convergence and divergence between these neighboring states is essential for practitioners handling cross-border matters.
Key Takeaway: Florida’s 2023 tort reform (HB 837) aligned its comparative negligence and statute of limitations rules with Georgia’s framework, but Florida retains pure comparative negligence for medical malpractice claims, operates a mandatory no-fault auto insurance system, and maintains highly restrictive dram shop liability. These differences create materially different litigation environments for specific case types.
Important Note: This guide addresses substantive law differences. Choice-of-law analysis and federal diversity jurisdiction implications are beyond this scope but must be considered for cases with multi-state contacts, particularly given the substantial interstate traffic between Georgia and Florida.
CRITICAL UPDATE: Georgia 2025 Tort Reform (SB 68)
Effective April 21, 2025, Georgia enacted comprehensive tort reform through Senate Bill 68. Practitioners must understand these changes: procedural provisions (anchoring, voluntary dismissal, bifurcation, discovery stay) apply immediately to pending cases, while substantive provisions (phantom damages, negligent security, seatbelt evidence) apply prospectively to causes of action or filings after the effective date.
Key Changes Summary
| Reform | Statute | Effective Date | Applies To |
|---|---|---|---|
| Anchoring Restrictions | § 9-10-184 | April 21, 2025 | All pending cases |
| Phantom Damages | § 51-12-1.1 | April 21, 2025 | Causes of action arising after 4/21/25 |
| Voluntary Dismissal Limits | § 9-11-41 | April 21, 2025 | All pending cases |
| Bifurcated Trials | § 51-12-15 | April 21, 2025 | All pending cases |
| Negligent Security Reform | §§ 51-3-50 to 51-3-57 | April 21, 2025 | Causes of action arising after 4/21/25 |
| Seatbelt Evidence | § 40-8-76.1 | April 21, 2025 | Actions filed after 4/21/25 |
| Discovery Stay (MTD) | § 9-11-12(j) | April 21, 2025 | All pending cases |
| Litigation Financing | SB 69 | January 1, 2026 | Per statute |
1. Anchoring Restrictions (O.C.G.A. § 9-10-184)
What Changed: Counsel may no longer argue, elicit testimony about, or reference the worth or monetary value of noneconomic damages until after the close of evidence. Even then, arguments must be “rationally related” to the evidence presented.
Practical Impact: No references to celebrity salaries, luxury items, or arbitrary anchors during trial. No voir dire questions about noneconomic damage amounts.
Florida Comparison: Florida has no statutory anchoring restrictions comparable to Georgia’s new law. Plaintiff’s counsel retains latitude to suggest specific damage figures during closing arguments.
2. Phantom Damages / Medical Expenses (O.C.G.A. § 51-12-1.1)
What Changed: Special damages for medical expenses are now limited to the “reasonable value of medically necessary care” as determined by the trier of fact. The jury may consider amounts actually paid or necessary to satisfy charges.
LOP Discovery: Letters of protection and similar arrangements are now relevant and discoverable.
Florida Comparison: Florida’s HB 837 made similar changes regarding medical damages. Florida now limits evidence of medical expenses to amounts actually paid, not billed amounts. Letters of protection arrangements are discoverable.
3. Negligent Security Reform (O.C.G.A. §§ 51-3-50 to 51-3-57)
What Changed: Georgia created an entirely new statutory framework for negligent security claims with heightened foreseeability requirements, mandatory fault apportionment to criminal perpetrators, and multiple safe harbors.
Florida Comparison: Florida’s HB 837 also addressed negligent security, imposing fault apportionment requirements to criminal perpetrators in premises liability cases. Both states now require consideration of criminal actor fault.
4. Seatbelt Evidence (O.C.G.A. § 40-8-76.1)
What Changed: Evidence of failure to wear a seatbelt is now admissible in Georgia on negligence, comparative negligence, causation, assumption of risk, and apportionment of fault.
Florida Comparison: Florida permits seatbelt evidence on the issue of comparative negligence and mitigation of damages. Both states now allow consideration of seatbelt non-use.
CRITICAL UPDATE: Florida 2023 Tort Reform (HB 837)
Effective March 24, 2023, Florida enacted comprehensive tort reform through House Bill 837 that fundamentally altered the state’s personal injury landscape.
Key Changes
| Reform | Effect | Key Detail |
|---|---|---|
| Comparative Negligence | Changed from pure to modified (51% bar) | Medical malpractice EXCEPTION: remains pure comparative |
| Statute of Limitations | Reduced from 4 years to 2 years | Applies to actions accruing on/after 3/24/23 |
| Bad Faith Timeline | Extended insurer response time | 90-day safe harbor for claims handling |
| Medical Damages | Limited to amounts actually paid | Billed amounts no longer recoverable |
| Premises Liability | Criminal actor fault considered | Apportionment required |
Transition Rules
Comparative Negligence: Modified (51% bar) applies to causes of action accruing on or after March 24, 2023. Claims accruing before that date remain under pure comparative negligence.
Statute of Limitations: 2-year period applies to causes of action accruing on or after March 24, 2023. Claims accruing before that date retain the 4-year period.
1. Negligence Systems: Post-Reform Convergence with Critical Exception
Georgia: Modified Comparative Negligence (50% Bar)
Georgia follows a modified comparative negligence system under O.C.G.A. § 51-12-33:
The 50% Bar Rule: A plaintiff may recover damages only if their fault is less than 50%. At exactly 50% or greater fault, the plaintiff is completely barred from recovery.
Proportional Reduction: When recovery is permitted, damages are reduced by the plaintiff’s percentage of fault.
Practical Application: If a plaintiff is found exactly 50% at fault, they recover nothing.
Florida: Modified Comparative Negligence (51% Bar) with Medical Malpractice Exception
Florida now follows a modified comparative negligence system under Fla. Stat. § 768.81 as amended by HB 837:
The 51% Bar Rule: A plaintiff may recover damages only if their fault is not greater than 50%. A plaintiff at exactly 50% fault can recover.
CRITICAL EXCEPTION: Medical malpractice claims remain subject to pure comparative negligence. Even a plaintiff found 99% at fault can recover 1% of damages in a medical malpractice case.
Proportional Reduction: Damages are diminished in proportion to the plaintiff’s percentage of fault.
Effective Date: Applies to causes of action accruing on or after March 24, 2023.
The Critical Difference
| Plaintiff Fault | Georgia Recovery | Florida Recovery (General) | Florida Recovery (Med Mal) |
|---|---|---|---|
| 49% | Yes (51% of damages) | Yes (51% of damages) | Yes (51% of damages) |
| 50% | NO | Yes (50% of damages) | Yes (50% of damages) |
| 51% | No | No | Yes (49% of damages) |
| 75% | No | No | Yes (25% of damages) |
Strategic Implications:
- For cases where plaintiff fault hovers around 50%, Florida offers slightly better odds (recovery permitted at exactly 50%)
- For medical malpractice cases with significant plaintiff fault, Florida’s pure comparative retention provides substantial advantages unavailable in Georgia
Joint and Several Liability
Georgia: Joint and several liability largely abolished; defendants generally liable only for their proportionate share.
Florida: Modified joint and several liability. Defendants more than 50% at fault are jointly and severally liable for economic damages; all defendants liable only for their proportionate share of noneconomic damages.
2. Statutes of Limitations: Now Aligned (With Exceptions)
General Personal Injury
| Claim Type | Georgia | Florida (Post-HB 837) |
|---|---|---|
| General negligence | 2 years (O.C.G.A. § 9-3-33) | 2 years (Fla. Stat. § 95.11) |
| Property damage | 4 years (O.C.G.A. § 9-3-30) | 4 years (Fla. Stat. § 95.11) |
| Wrongful death | 2 years (O.C.G.A. § 9-3-33) | 2 years (Fla. Stat. § 95.11) |
Critical Note: Florida’s negligence SOL was 4 years before March 24, 2023. Cases accruing before that date retain the 4-year period.
Medical Malpractice
Georgia (O.C.G.A. § 9-3-71):
- General rule: 2 years from injury
- Statute of repose: 5 years maximum from negligent act
- Foreign object exception: 1 year from discovery, no repose limit
- Minors: Tolled until age 5, then 2 years (action must be filed by age 7 for injuries before age 5)
Florida (Fla. Stat. § 95.11):
- General rule: 2 years from discovery or when should have been discovered
- Statute of repose: 4 years from incident
- Fraud/concealment exception: Repose extends to 7 years if provider concealed malpractice
- Minors: Special provisions for children under age 8
Critical Differences:
- Both states have 2-year discovery-based limitations
- Georgia has longer repose (5 years) than Florida (4 years)
- Florida’s fraud exception extending to 7 years provides protection in concealment cases
Government Claims
Georgia:
- Ante litem notice: Generally within 12 months (O.C.G.A. § 36-33-5 for municipalities)
- Georgia Tort Claims Act governs state claims
Florida (Fla. Stat. § 768.28):
- Written notice required within 3 years of claim accrual
- Notice must be presented to appropriate agency AND Department of Financial Services
- 6-month investigation period before suit may be filed
- Damage Cap: $200,000 per person, $300,000 per incident
- Excess claims must be approved by Legislature through claims bill process
Critical Difference: Florida’s damage caps on government claims ($200,000/$300,000) significantly limit recovery compared to Georgia’s higher caps under the Georgia Tort Claims Act ($1,000,000/$3,000,000).
3. Damage Caps and Limitations
Noneconomic Damages
Georgia: No statutory cap on noneconomic damages in personal injury cases. Georgia’s medical malpractice cap was struck down as unconstitutional in Atlanta Oculoplastic Surgery, P.C. v. Nestlehutt (2010), 286 Ga. 731.
Florida: No statutory cap on noneconomic damages in general personal injury cases. Florida’s medical malpractice caps were struck down as unconstitutional in:
- Estate of McCall v. United States (2014) for wrongful death
- North Broward Hospital District v. Kalitan (2017) for general medical malpractice claims
HB 837 did not reinstate damage caps, leaving both states without statutory limitations on noneconomic damages.
Government Liability Caps
| Entity | Georgia | Florida |
|---|---|---|
| State claims | $1,000,000 per person | $200,000 per person |
| Per incident | $3,000,000 | $300,000 |
| Excess recovery | By approval | Claims bill to Legislature |
Strategic Consideration: Florida’s low government liability caps make Georgia a significantly more favorable forum for cases involving state or local government defendants.
Punitive Damages
Georgia (O.C.G.A. § 51-12-5.1):
- Standard: Willful misconduct, malice, fraud, wantonness, oppression, or conscious indifference
- Cap: Generally $250,000 unless specific intent to harm, DUI involvement, or product liability
- Allocation: 75% to state treasury, 25% to plaintiff (unless product liability)
- Bifurcation available
Florida (Fla. Stat. § 768.73):
- Standard: Intentional misconduct or gross negligence
- Cap: Generally 3x compensatory damages or $500,000, whichever is greater
- Alternative cap: 4x compensatory or $2,000,000 for conduct motivated primarily by unreasonable financial gain
- No state allocation requirement
- Bifurcation required upon request
Comparison:
| Factor | Georgia | Florida |
|---|---|---|
| General cap | $250,000 | 3x compensatory or $500,000 |
| State allocation | 75% | None |
| Bifurcation | Available | Required upon request |
| DUI exception | Yes (no cap) | No specific exception |
4. Auto Insurance Requirements and No-Fault System
Georgia: Traditional Fault State
Minimum Liability Requirements (O.C.G.A. § 33-7-11):
- $25,000 per person bodily injury
- $50,000 per accident bodily injury
- $25,000 property damage
- Written as 25/50/25
Uninsured/Underinsured Motorist: Not mandatory but must be offered; can be rejected in writing.
No-Fault: Georgia is a traditional fault state with no PIP requirement.
Florida: No-Fault State with Limited Tort Rights
Minimum Requirements:
- $10,000 PIP (Personal Injury Protection)
- $10,000 PDL (Property Damage Liability)
- NO bodily injury liability requirement for standard drivers (required after DUI or certain violations)
PIP Coverage Details (Fla. Stat. § 627.736):
- Covers 80% of reasonable medical expenses up to $10,000
- $10,000 limit only if diagnosed with “Emergency Medical Condition”
- $2,500 limit if injuries are not an Emergency Medical Condition
- 14-day rule: Treatment must be sought within 14 days of accident to receive PIP benefits
- Covers lost wages (60% up to $10,000 total with medical)
Tort Threshold: To step outside no-fault and pursue pain and suffering damages against at-fault driver, injuries must result in:
- Significant and permanent loss of an important bodily function
- Permanent injury within a reasonable degree of medical probability
- Significant and permanent scarring or disfigurement
- Death
Comparison
| Coverage | Georgia | Florida |
|---|---|---|
| Bodily injury (per person) | $25,000 | Not required |
| Bodily injury (per accident) | $50,000 | Not required |
| Property damage | $25,000 | $10,000 |
| PIP required | No | Yes ($10,000) |
| System type | Fault | No-Fault |
| Pain/suffering threshold | None | Permanent injury threshold |
Practical Implications:
- Many Florida drivers carry only PIP and property damage; no bodily injury coverage
- Georgia plaintiffs injured in Florida may face uninsured defendant scenarios
- Florida’s 14-day rule can bar PIP benefits if medical treatment is delayed
- Florida’s tort threshold can bar pain and suffering claims for soft tissue injuries
5. Dog Bite Liability
Georgia: Traditional Negligence with Statutory Elements
Under O.C.G.A. § 51-2-7, Georgia imposes liability for dog bites when:
- The dog is vicious or dangerous
- The owner knew or should have known of this propensity
- The owner was negligent in managing the dog
First Bite Context: Knowledge of dangerousness can be proven through prior incidents, breed characteristics, or other evidence of vicious propensity.
Florida: Strict Liability with Comparative Negligence
Florida imposes strict liability for dog bites under Fla. Stat. § 767.04:
Strict Liability Standard: The owner of any dog is liable for damages suffered by any person bitten by the dog while in a public place or lawfully in a private place, regardless of the former viciousness of the dog or the owner’s knowledge of such viciousness.
Comparative Negligence Applies: Any negligence on the part of the victim is compared pursuant to Fla. Stat. § 768.81 and reduces the owner’s liability.
“Bad Dog” Sign Defense: If the owner prominently displays a sign including the words “Bad Dog,” the owner is not liable, unless:
- The victim is under 6 years of age
- The owner’s negligence was a proximate cause of the biting incident
Statute of Limitations: 2 years (post-HB 837)
Comparison
| Factor | Georgia | Florida |
|---|---|---|
| Standard | Negligence + knowledge | Strict liability |
| First bite defense | Potentially available | Not available |
| Comparative negligence | Applies | Applies |
| Warning sign defense | No | Yes (Bad Dog sign) |
| SOL | 2 years | 2 years |
Strategic Advantage: Florida’s strict liability standard significantly favors plaintiffs by eliminating the need to prove owner knowledge, but the “Bad Dog” sign defense and comparative negligence application can reduce or eliminate recovery in certain circumstances.
6. Dram Shop and Social Host Liability
Georgia: Broad Dram Shop Liability
Georgia provides for dram shop liability under O.C.G.A. § 51-1-40:
Commercial Vendors:
- Liable for selling, furnishing, or serving alcohol to persons under 21
- Liable for serving noticeably intoxicated persons when the provider knows the person will soon drive
- Requires knowledge or reasonable cause to believe the condition exists
Third-Party Claims: Injured third parties may recover against the establishment that over-served.
Florida: Highly Restrictive Dram Shop Liability
Florida’s dram shop law (Fla. Stat. § 768.125) is among the most restrictive in the nation:
General Rule: A person who sells or furnishes alcoholic beverages to a person of lawful drinking age shall NOT be liable for injury or damage caused by that person’s intoxication.
Two Narrow Exceptions:
- Serving Minors: Willfully and unlawfully selling or furnishing alcohol to someone under 21
- Serving Habitual Addicts: Knowingly serving someone who is “habitually addicted” to alcohol
Critical Limitation: Simply serving a visibly intoxicated adult does NOT create liability in Florida. The establishment must have actual knowledge that the patron is habitually addicted to alcohol.
Social Host Liability: Florida does not impose social host liability for serving alcohol to adults, even if intoxicated.
Comparison
| Factor | Georgia | Florida |
|---|---|---|
| Liability for over-serving adults | Yes (if visibly intoxicated + will drive) | NO (requires “habitual addict” knowledge) |
| Liability for serving minors | Yes | Yes |
| Social host liability | Limited | None |
| Proof burden | Knowledge of intoxication | Knowledge of habitual addiction |
Critical Strategic Difference: Georgia’s dram shop statute is substantially broader than Florida’s. Cases involving intoxicated drivers where the establishment over-served should strongly consider Georgia forum if choice of law permits. Florida’s requirement to prove the patron was a “habitual addict” known to the establishment creates a nearly insurmountable barrier for most dram shop claims.
7. Sovereign Immunity and Government Liability
Georgia: Higher Caps
Georgia Tort Claims Act (O.C.G.A. § 50-21-20 et seq.):
- Waives immunity for state torts up to $1,000,000 per person, $3,000,000 per occurrence
- Extensive exceptions including discretionary functions
- Requires written ante litem notice
Municipal Liability (O.C.G.A. § 36-33-1 et seq.):
- Waived for ministerial acts
- Discretionary function immunity retained
- Ante litem notice required (generally 6-12 months)
Florida: Lower Caps, Claims Bill Process
Florida Sovereign Immunity Waiver (Fla. Stat. § 768.28):
- Waives immunity for state and subdivision torts
- Caps: $200,000 per person, $300,000 per incident
- Notice required within 3 years; must go to both agency and Department of Financial Services
- 6-month investigation period before suit
Claims Bill Process:
- Judgments exceeding caps may be presented to Legislature
- Legislature must pass a claims bill authorizing payment
- No guarantee of recovery beyond caps
Employees: State employees acting within scope of employment are personally immune; state is exclusive defendant.
Comparison
| Factor | Georgia | Florida |
|---|---|---|
| Per person cap | $1,000,000 | $200,000 |
| Per incident cap | $3,000,000 | $300,000 |
| Excess recovery | By approval | Claims bill (uncertain) |
| Notice period | 6-12 months | 3 years |
| Discretionary immunity | Yes | Yes |
Strategic Consideration: Georgia’s government liability caps are five times higher than Florida’s. Cases involving government defendants should strongly favor Georgia forum when possible.
8. Wrongful Death and Survival Actions
Georgia
Wrongful Death (O.C.G.A. § 51-4-1 et seq.):
- Brought by surviving spouse; if none, children; if none, parents; if none, estate
- Recovers the “full value of the life” of the decedent
- Includes economic and non-economic damages
- Does not recover decedent’s pre-death pain and suffering (separate survival action required)
Survival Action: Estate may pursue damages decedent could have recovered had they survived.
Statute of Limitations: 2 years from date of death.
Florida
Wrongful Death (Fla. Stat. § 768.16-768.26):
- Brought by personal representative on behalf of estate and survivors
- Survivors include spouse, children, parents (if no spouse/children), and dependent blood relatives or adoptive siblings
Recoverable Damages Vary by Survivor:
- Spouse: Loss of support, services, companionship, mental pain and suffering
- Minor children: Lost support, services, parental companionship, instruction, guidance, mental pain and suffering
- Adult children: Mental pain and suffering only if no spouse or minor children
- Parents: Mental pain and suffering only if no spouse or minor children
Survival Action: Estate may recover loss of earnings, medical expenses, and pain and suffering from injury to death.
Statute of Limitations: 2 years from date of death.
Key Differences
| Factor | Georgia | Florida |
|---|---|---|
| Who brings suit | Statutory beneficiaries | Personal representative |
| Measure of damages | Full value of life | Lost support/services + mental pain |
| Adult children recovery | Through estate | Limited unless no spouse/minor children |
| Pain and suffering | Separate survival action | Survival action (injury to death) |
| SOL | 2 years from death | 2 years from death |
9. Medical Malpractice: Critical Comparative Negligence Difference
Georgia Requirements
Affidavit Requirement (O.C.G.A. § 9-11-9.1):
- Expert affidavit required at filing (contemporaneous filing)
- Must identify one negligent act and state that the affiant believes the act is the proximate cause of plaintiff’s injury
- Expert must be competent to testify
Comparative Negligence: Modified (50% bar) applies to medical malpractice claims.
Damage Caps: None (struck down as unconstitutional).
Florida Requirements
Pre-Suit Investigation (Fla. Stat. § 766.106):
- 90-day pre-suit notice and investigation period required
- Defendant must respond within 90 days with rejection, admission, or settlement offer
- Failure to comply affects attorney’s fees
Expert Opinion: Pre-suit verified written expert opinion required.
Comparative Negligence: Pure comparative negligence retained for medical malpractice (HB 837 exception).
Damage Caps: None (struck down as unconstitutional).
Comparison
| Factor | Georgia | Florida |
|---|---|---|
| Pre-suit notice | No | 90-day investigation period |
| Expert affidavit timing | At filing | Pre-suit |
| Comparative negligence | Modified (50% bar) | Pure |
| Damage caps | None | None |
| Statute of repose | 5 years | 4 years |
Critical Strategic Consideration: Florida’s retention of pure comparative negligence for medical malpractice claims creates a significant advantage for plaintiffs with contributory fault. A plaintiff found 70% at fault in a Georgia medical malpractice case recovers nothing; the same plaintiff recovers 30% of damages in Florida.
10. Forum Selection Considerations
Factors Favoring Georgia Forum
- Dram shop cases: Georgia’s broader liability for serving visibly intoxicated patrons
- Government claims: $1M/$3M caps vs. Florida’s $200K/$300K caps
- Guaranteed bodily injury coverage: All Georgia drivers must carry BI liability
- Medical malpractice with low plaintiff fault: Modified comparative bars high-fault plaintiffs
- Longer medical malpractice repose: 5 years vs. 4 years
Factors Favoring Florida Forum
- Medical malpractice with significant plaintiff fault: Pure comparative negligence retained
- 50% fault recovery: Plaintiff at exactly 50% fault recovers in Florida, not Georgia
- Dog bite strict liability: Eliminates proof of knowledge/dangerous propensity
- Punitive damages: Higher caps (3x compensatory vs. $250,000)
- No state allocation of punitive damages: Plaintiff keeps full award
Practical Considerations
For Middle Georgia practitioners representing clients with Florida connections:
- Interstate accidents: I-75 and I-95 corridor accidents may involve both states’ laws
- Snowbird clients: Georgia residents injured in Florida face no-fault system complications
- Florida’s 14-day PIP rule: Advise clients to seek immediate treatment to preserve benefits
- Uninsured drivers: Higher risk in Florida due to no mandatory BI coverage
11. Comparative Summary Table
| Category | Georgia | Florida | Advantage |
|---|---|---|---|
| Comparative Negligence | 50% bar (less than) | 51% bar (not greater than) | Florida (50% recovery allowed) |
| Med Mal Comparative | Modified (50% bar) | Pure | Florida (high-fault plaintiffs) |
| General PI SOL | 2 years | 2 years | Equal |
| Med Mal Repose | 5 years | 4 years | Georgia |
| Government Caps | $1M/$3M | $200K/$300K | Georgia |
| Dog Bite Standard | Negligence + knowledge | Strict liability | Florida |
| Dram Shop Liability | Broad | Highly restrictive | Georgia |
| Auto Insurance System | Fault (25/50/25 required) | No-Fault (no BI required) | Georgia |
| Punitive Damage Cap | $250,000 (exceptions apply) | 3x compensatory or $500,000 | Florida |
| Punitive State Allocation | 75% | None | Florida |
Sources
Georgia Code (O.C.G.A.):
- § 51-12-33 (Comparative Negligence)
- § 9-3-33 (Personal Injury SOL)
- § 9-3-71 (Medical Malpractice SOL)
- § 51-2-7 (Dog Bite Liability)
- § 51-1-40 (Dram Shop Liability)
- § 51-12-5.1 (Punitive Damages)
- § 50-21-20 et seq. (Georgia Tort Claims Act)
- § 33-7-11 (Auto Insurance Requirements)
- Senate Bill 68 (2025 Tort Reform)
Florida Statutes:
- § 768.81 (Comparative Negligence, as amended by HB 837)
- § 95.11 (Statutes of Limitations, as amended by HB 837)
- § 768.28 (Sovereign Immunity Waiver)
- § 767.04 (Dog Bite Strict Liability)
- § 768.125 (Dram Shop Liability)
- § 768.73 (Punitive Damages)
- § 627.736 (PIP Coverage)
- § 766.106 (Medical Malpractice Pre-Suit Requirements)
- House Bill 837 (2023 Tort Reform)
Case Law:
- Atlanta Oculoplastic Surgery, P.C. v. Nestlehutt, 286 Ga. 731 (2010)
- Estate of McCall v. United States, 134 So. 3d 894 (Fla. 2014)
- North Broward Hospital District v. Kalitan, 219 So. 3d 49 (Fla. 2017)
This guide is current as of January 2026. Practitioners should verify current statutory language and recent case law developments before relying on this information for specific cases.