Jason Azzarone and Barbara Chapman were successful in arguing to the Second District Court of Appeal that the trial court erred in denying a motion to dismiss for failure to comply with the medical malpractice presuit screening requirements in Corbo v. Garcia, 949 So. 2d 366 (Fla. 2d DCA 2007). The Plaintiff allegedly received burns to her arms when she was connected to a physical therapy machine that provided electrical stimulation. The Plaintiff brought a negligence action against the physical therapist and his practice alleging failure to properly maintain the machine. The Second District Court of Appeal agreed that the Plaintiff’s claim arose out of the rendering of medical treatment and thus was subject to the presuit screening requirements.