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.
| Digital ExclusiveCourt Rules Against No-Fault Insurers - Again
New York's highest court of appeals has held that no-fault insurers cannot deny no-fault benefits where they unilaterally determine that a provider has committed misconduct based upon alleged fraudulent conduct.
Per the 6-1 decision, such payments may only be withheld after a state regulator determines that the provider committed professional misconduct resulting in suspension, revocation or annulment of their medical license. (Government Employees Insurance Company v. Mayzenberg, 2025 NY Slip Op 06527; published 11/24/25)
Thus, the Court held that this authority belongs solely to state regulators, specifically New York's Board of Regents, which oversees professional licensing and discipline. The only carve out to this rule is if there is conclusive proof that a layperson is controlling the medical practice.
This follows a similar recent ruling in Florida reported in Dynamic Chiropractic (“A Groundbreaking Case for Chiropractic”; Read Here).