Claims for harm from Allergan implants in Florida

Florida plaintiffs may join MDL 2921 (D.N.J., Judge Brian R. Martinotti) or file in Florida state court. Florida state court does not have a coordinated BIOCELL proceeding as of early 2026. Federal filings in Florida originate in the Southern District of Florida (Miami Division) or Middle District of Florida (Tampa or Orlando Divisions) before JPML transfer to New Jersey. Florida is among the top three states by plaintiff volume in MDL 2921.

Florida's statute of limitations for personal injury is four years under Fla. Stat. § 95.11(3)(a), one of the longest in the country and favorable for BIOCELL plaintiffs with delayed diagnoses. Florida also recognizes the delayed-discovery rule for latent disease: the limitations period runs from when the plaintiff knew or should have known of the injury. For BIA-ALCL, this is generally the diagnosis date. Note that Florida amended its products liability statute in 2023 (HB 837); plaintiffs should confirm applicable limitation periods based on their implant and diagnosis dates.

Key Florida venues include Miami-Dade Circuit Court (Complex Business Litigation Section), Broward County Circuit Court (Fort Lauderdale), Palm Beach County Circuit Court, and Hillsborough County Circuit Court (Tampa). In federal court, Southern District of Florida Judge Cecilia Altonaga (Miami) and Middle District of Florida judges in Tampa regularly handle complex product liability matters prior to MDL transfer. Florida applies the Daubert standard for expert testimony under § 90.702, amended in 2013.

Florida's BIOCELL exposure is heavily concentrated in South Florida (Miami-Dade, Broward, Palm Beach counties), Tampa Bay, and Orlando. South Florida's large cosmetic surgery market — driven by plastic surgery practice density in Miami Beach, Boca Raton, and Fort Lauderdale — resulted in high BIOCELL implant placement rates. Florida also has a significant international patient population for cosmetic procedures, which can create service-of-process and jurisdiction considerations for certain defendants.