Michael J. Schroeder, Esq.
| DIGITAL EXCLUSIVE
On Oct. 21, 2025, a judge in Florida issued a groundbreaking decision in Complete Care v State Farm, 25-CA-1063. It concerns a fact pattern that many chiropractic doctors have faced wherein an insurer, such as State Farm or Allstate, decides to simply stop paying all claims submitted by a healthcare provider.
The Case Details
On April 3, 2025, State Farm decided to stop paying all claims, no matter how meritorious, submitted by Complete Care, amounting to over $600,000 a month, due to alleged fraud by Complete Care. (Complete Care is a network of 30 rehab clinics that include chiropractic as a primary form of care.) The alleged fraud was “the delayed collection of deductibles and coinsurance from their patients.”
Complete Care pointed out that it requires every patient to sign a written contract that each patient is liable for deductibles/co-pays and collects 86% of them, a better percentage than most clinics.
Judge Paul Huey, when faced with these facts, found that State Farm had issued a private mandatory injunction against Complete Care without getting a court’s approval and did so without a factual basis. He found that “State Farm needs probable cause before it can trample a citizen’s rights.”
State Farm had sent letters to every Complete Care patient insured by State Farm, stating that State Farm would not pay their claim because State Farm was suing Complete Care (the “Breach Letters”). Paradoxically, these Breach Letters by State Farm caused some patients to not pay their copays.
The judge then did something unique. In an unprecedented ruling, he issued an injunction against State Farm 1) stopping State Farm’s private injunction of not paying Complete Care claims; 2) barring State Farm from sending out any further Breach Letters encouraging patients to not pay their copays; 3) requiring State Farm to send a letter to everyone who got the Breach Letter advising them to pay their copays/deductibles; and 4) requiring State Farm to pay all of Complete Care’s outstanding claims.
Why This Matters
The court treated the private injunctions State Farm and Allstate have been known to issue frequently as illegal. This decision is a legal tool all healthcare providers, including chiropractic doctors, can use to fight this type of abuse. While Complete Care is better funded to fight this battle than most individual chiropractic doctors, all DCs can band together through their state and national associations using this legal tool.
Editor’s Note: This column by the National Association of Chiropractic Attorneys (NACA: https://nacattorneys.com/) features legal updates as they relate to chiropractors. For previous articles, visit the NACA online columnist page.
