Choate flew back to Miami from Colorado to have his elbow examined by team doctors Thursday.
Choate told team officials he felt tightness in his elbow after his last outing Monday night. Choate faced just one batter and allowed Jason Giambi's game-ending, three-run homer in the ninth inning of a 7-4 loss at Colorado.
The Marlins have lost two relievers in the past two days with Brian Sanches (right elbow strain) also being put on the DL Wednesday.
Right-handed rookie pitcher Chris Hatcher was recalled from Double-A Jacksonville to replace Choate.
Choate is 1-1 with a 1.82 ERA in 54 appearances this season.