CARMEN DANIELLE MORA SANCHEZ v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, ET AL. Settlement

If you received a notice identifying you as a Settlement Class Member, you are eligible for a cash payment because of the settlement of a class action lawsuit involving driver’s license suspensions. The lawsuit was filed against State Farm Mutual Automobile Insurance Company (“State Farm”) and Hiday & Ricke, P.A., and Jeff Ricke (the “Hiday & Ricke Defendants”) by Carmen Danielle Mora Sanchez, Brandon Rashard Waters, and Kashana Sangfield (collectively, the “Plaintiffs”) in the federal court for the Middle District of Florida (the “Court”) and is titled Carmen Danielle Mora Sanchez, et al. v. State Farm Mut. Auto. Ins. Co., et al. (Case No. 3:21-cv-372-TJC-LLL) (M.D. Fla.) (the “Action”). Together, State Farm and the Hiday & Ricke Defendants are referred to as the “Defendants.” Capitalized terms not otherwise defined herein are defined in the Class Action Settlement Agreement executed by the Parties.

A class action is a kind of lawsuit. In a class action, the rights of a large group of people are decided in one court proceeding. Representative plaintiffs known as “class representatives” assert claims on behalf of the entire group, or “class.”

Plaintiffs sued Defendants in a class action lawsuit challenging their conduct in connection with collection of judgments against Plaintiffs arising out of Plaintiffs’ accidents with persons insured by State Farm.  In particular, Plaintiffs contend that Defendants improperly pursued the suspension of their drivers’ licenses and others because at the time of their accidents they maintained the minimum required insurance required by Florida law.  Pursuant to Fla. Stat. § 324.021(7) (2017 to date), the minimum insurance is: (a) In the amount of $10,000 because of bodily injury to, or death of, one person in any one crash; (b) Subject to such limits for one person, in the amount of $20,000 because of bodily injury to, or death of, two or more persons in any one crash; (c) In the amount of $10,000 because of injury to, or destruction of, property of others in any one crash; and (d) With respect to commercial motor vehicles and nonpublic sector buses, in the amounts specified in §§ 627.7415 and 627.742, respectively. See Fla. Stat. § 324.021(7). Plaintiffs brought the following claims against the Defendants on behalf of the Settlement Class: violation of the Florida Consumer Collections Practices Act; common law conversion; aiding and abetting conversion; economic duress; violation of the federal RICO Act (18 U.S.C. § 1962(c)); violation of the federal RICO Act (18 U.S.C. § 1962(d)); abuse of process; unjust enrichment; and declaratory relief.

Defendants have denied all material allegations asserted in the Action and maintain that they acted in accordance with all applicable laws.

You are in the Settlement Class in the Action if you meet the following criteria:

Excluded from the Settlement Class are:

• Any in-house or outside counsel for the Defendants and the immediate family members of such persons;
• Employees of the Defendants;
• Any members of the judiciary assigned to the Action and their staff; and
• The Parties’ counsel in the Action.

The Court has approved (and the Parties have agreed) that the Settlement Class is the group of people comprised of the four hundred and forty-one (441) persons identified as a result of the Hiday & Ricke Defendants’ search of their records.

The Court has appointed the Plaintiffs as the representatives of the Settlement Class. The Court has also appointed the following lawyers as counsel for the Settlement Class (“Class Counsel”):

These lawyers represent your interest in the Action. You will not be charged for their services.

Drivers License Reinstatement 

If you are a class member, you may have already had your driver’s license reinstated if your suspension was solely related to the Defendants’ requests for suspension.  If your driver’s license was suspended for any other reason, then it may still be suspended. You can confirm the status of your driver’s license through the online DMV Portal at: https://mydmvportal.flhsmv.gov . 

Removal of SR22 Insurance Obligations 

SR22 insurance provides the DMV with a certificate of your financial responsibility with respect to car insurance. As a result of your driver’s license suspension, you may have paid or are currently paying for SR22 insurance. In addition to the monetary relief described below, any SR22 insurance requirements that arose due to Defendants’ requests for suspension should have already been removed from your DMV record. You can contact the DMV to confirm you are no longer required to carry SR22 insurance and, if you are paying such premiums and are not required to pay such premiums, you may cancel the SR22 portion of your insurance. If you previously paid for SR22 insurance as result of Defendants’ suspension requests, you may seek reimbursement of that portion of those expenses through this Settlement. 

After extensive negotiations, the Parties have agreed to settle the case. Under the Proposed Settlement, Defendants have agreed to send cash payments to all Settlement Class Members who do not exclude themselves from the Settlement Class in the amount of One Thousand, Five Hundred Dollars ($1,500.00) (the “Initial Payments”).

With an Initial Payment, Settlement Class Members who do not exclude themselves from the Settlement Class will be provided a Claim Form and the opportunity to submit a claim for additional monetary relief (a “Claim for Payment of Additional Relief”). Only timely and complete Claim Forms submitted by or before the Claims Submission Deadline may be considered for payment on a Claim for Payment of Additional Relief. Any awards on such Claims for Payment of Additional Relief shall be determined by a Special Master selected by the Parties and approved by the Court. 

Defendants have agreed to fund the Settlement up to the amount of Four Million  Sixteen Thousand Five Hundred Dollars ($4,016,500.00). Funding for Claims for Payment of Additional Relief shall be paid out of any funds remaining after the payment of the Initial Payments, Service Awards to the Plaintiffs, Plaintiffs’ attorneys’ fees and costs, and the administrative costs of the Settlement. If the monetary total of all Claims for Payment of Additional Relief approved by the Special Master exceeds the funding amounts remaining after the payment of the Initial Payments, Plaintiffs’ attorneys’ fees and costs, the Service Awards to the Plaintiffs, and any administrative costs, the approved Claims for Payment of Additional Relief shall be adjusted on a pro rata basis out of the funds available.

As part of the Agreement, Defendants have agreed not to seek the suspension of the driver’s licenses of any class members in connection with any judgment amounts that may still be owed.   However, this Settlement does not cancel or settle any judgment amounts that may still be owed; and Defendants are entitled to pursue all other viable methods to recover those amounts. In addition, Defendants also agree not to seek the suspension of any debtor’s driver’s license pursuant to Chapter 324 of the Florida Statutes if the judgment debtor maintained the minimum insurance required pursuant to Fla. Stat. § 324.021(7) at the time of the accident with a State Farm insured giving rise to a State Farm Judgment and such person (or their automobile insurer) tenders such funds to State Farm or its counsel in full or partial satisfaction of the debt owing to State Farm.

While the Court has preliminarily approved the Settlement, it has not yet finally approved the Settlement. No payments will be issued until after the Court has finally approved the Settlement and entered a Final Order and Judgment.

If the Settlement is not finally approved by the Court, no payments will be issued and the Parties and the members of the Settlement Class will be returned to the status quo as it existed on January 15, 2025.

The Settlement provides for a release of claims against the Defendants. Specifically, if the Settlement is finally approved, Plaintiffs and each Settlement Class Member (except Settlement Class Members who have excluded themselves from the Settlement Class) will release Defendants and related persons and entities from all legal claims that they have or could have asserted in this lawsuit, arising out of or relating to any claim covered by the Settlement concerning the suspension of their drivers’ licenses in connection with a State Farm Judgment.

If you are a Settlement Class Member, you have a right to stay in the case as a Settlement Class Member, or you can choose to be excluded from the case. You need to decide this question very soon.

Option 1. Do Nothing Now. Stay in the Action and Receive an Initial Settlement Payment of $1,500 and the Opportunity to Submit a Claim for Additional Cash Relief

You have the right to stay in this Action as a Settlement Class Member and wait for final approval of the Settlement. You do not need to do anything if you wish to remain in this case. It will cost you nothing. If you do nothing, and after the Settlement is finally approved, you will automatically receive an Initial Payment in the amount of $1,500.00. With that payment, you will also receive a  Claim Form that you can submit in the event that you believe that you have additional damages and want to pursue a Claim for Payment of Additional Relief. If you decide to stay in the case as a Settlement Class Member, you will be bound by all orders and judgments of the Court with regard to the Settlement Class.

Option 2. Exclude yourself from the Action.

You have the right to not be part of this Action by excluding yourself or “opting out” of the Settlement Class. If you exclude yourself, you will not receive an Initial Payment of $1,500.00 and you will not have the ability to make a Claim for Payment of Additional Relief.  However, you will maintain your legal right to sue Defendants in a separate lawsuit at your own expense. 

If you wish to be excluded from the Settlement Class, you must send a written request for exclusion to: Sanchez v State Farm c/o Settlement Administrator, PO Box 23650, Jacksonville, FL 32241. All requests for exclusion must be postmarked on or before AUGUST 12, 2025. Your request for exclusion must contain all of the following:

• the name of the Action (“Sanchez v. State Farm Mutual Automobile Insurance Company (Case No. 3:21-cv-372-TJC-LLL) (M.D. Fla.)”);
• your full name (and your name at the time of the entry of the State Farm Judgment, if different from your current name);
• your current address (and your address at the time of the entry of the State Farm Judgment, if different from your current address);
• a clear statement that you wish to be excluded from the Settlement Class, such as: “I request exclusion from the Settlement Class”; and
• your signature

You do not need to hire your own lawyer to request exclusion from the Settlement Class. If you exclude yourself from the Settlement Class, you give up your right to receive money or other benefits awarded in this case, if any, and you will not be bound by any judgments or orders of the Court.

If the request for exclusion is submitted by someone other than the Settlement Class Member (i.e., a Legally Authorized Representative), then the third party signor (e.g., attorney, legal representative, or other third party) must include the following attestation on the exclusion request: “I certify and attest to the Court that the Settlement Class Member on whose behalf this exclusion request is submitted has been provided a copy of and an opportunity to read the Class Notice and thereafter specifically requested to be excluded from the Settlement Class.” Such third-party signor must include their full name, contact information, and the basis for that signor’s authority to act on behalf of the Settlement Class Member.

If you are a Settlement Class Member, and if you think the Proposed Settlement is unfair, you have the right to object to the Settlement. 

To object, you must submit a writing containing the following:

• a prominent identifying reference to the Action containing the title of the case, “Sanchez v. State Farm Mutual Automobile Insurance Company (Case No. 3:21-cv-372-TJC-LLL) (M.D. Fla.)”;
• your full legal name (and your name at the time of the entry of the State Farm Judgment, if different from yur current name);
• your current address (and your address at the time of the entry of the State Farm Judgment, if different from your current address) and telephone number;
• a statement of each objection being made and the basis therefor;
• a statement indicating whether you intend to appear at the Final Approval Hearing;
• a list of witnesses whom you may call by live testimony;
• if you are represented by legal counsel, the name, address, bar number, and telephone number of the counsel;
• any legal authority upon which you intend to rely in support of the objection; and
• copies of any documents or papers that you plan to submit or want the Court to consider.

Written objections must be filed with the Court and served upon all counsel in the Action by no later than JULY 15, 2025. If you do not comply with these procedures, including the deadline for submitting written objections, you will lose any opportunity to have your objection considered by the Court or to otherwise contest the approval of the Proposed Settlement or to appeal from any orders or judgments entered by the Court in connection with the Proposed Settlement.

The Court has scheduled a Final Approval Hearing for August 26, 2025 at 2:00 pm before the Honorable Timothy Corrigan. You do not need to attend the hearing. The Final Approval Hearing will address whether the Proposed Settlement is fair, reasonable, and adequate and whether the Court should approve it. The Final Approval Hearing date is subject to change. If the Final Approval Hearing date changes, no separate notice of that change will be mailed.  However, the new date will be available on this website.  

If the Settlement is finally approved without an appeal, Initial Payments may issue by 45 days after the entry of the Final Order and Judgment. If there is an appeal, Initial Payments would issue by 45 days after the appeal is finally resolved. The payment of Claims for Payment of Additional Relief will be dependent on the completion of the claims administration process to be overseen by the Special Master. If the Settlement is not approved by the Court, no payments will be issued. The Court may extend the payment period with approval from the Parties. If that happens, no separate notice of that change will be mailed.

The notice is a summary of the Action and the Proposed Settlement. A copy of this document a long with other court documents can be found on the Important Court Documents page of this website. 

If you have any questions about this notice or the Proposed Settlement, you may contact Class Counsel or the Settlement Administrator at: 

DO NOT CONTACT THE COURT OR DEFENDANTS OR DEFENDANTS’ COUNSEL FOR INFORMATION.