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On March 27, 2020, the Texas Supreme Court, in Farmers Texas County Mutual Insurance Company v. Beasley, No. 18-0469, decided whether “an injured plaintiff had standing to bring suit against his personal injury protection (PIP) policy insurer after the insurer paid the incurred medical expenses pursuant to the PIP policy, but the amount the PIP insurer paid was the negotiated rate between the plaintiff’s health care insurer and the medical providers—not the medical providers’ list rate.” The Court held that the insured plaintiff lacked standing because he was unable to allege he had suffered any threatened or actual injury as a result of his insurer’s PIP payments of the medical expenses actually incurred, rather than payment of the medical providers’ list rates that were not charged to, or incurred by, the insured.
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