On March 3, 2017, in Haney v. Sloan, No. 1D15-3905, the Florida First DCA reversed the trial court’s directed verdict on the amount of past medical expenses in a case involving medical treatment for two successive accidents. The First DCA observed that where a plaintiff has been involved in successive accidents but sues just one of the tortfeasors causing her injuries, it is the jury’s role to determine whether the plaintiff’s injuries can be apportioned between the first and second accident, and if the injuries cannot be apportioned, then in accordance with the indivisible injury rule the jury is to find the prior tortfeasor responsible for all of the injuries. See Gross v.
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