Auto Insurance
McGee v. Progressive Select Ins. Co., No. 8:25-cv-00868-JLB-NHA (M.D. Fla., Apr. 13, 2026 (Hirt Adams, J.)) (denying the plaintiff’s motion to compel production of Progressive’s Electronic File Folder (EFF) index, finding that the requested discovery was not relevant or proportional under Rule 26, and reasoning that Progressive had already produced all non‑privileged claim‑file documents and sworn testimony established that the EFF would neither reveal meaningful receipt‑date information nor demonstrate any omission in production, making further discovery duplicative and unhelpful. https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00868-56-8-cv
Commercial Property Insurance
Zain Beauty Supply, Inc. v. Ohio Security Ins. Co., No. 8:25-cv-01679-SDM-LSG (M.D. Fla., Apr. 13, 2026 (Merryday, J.)) (granting summary judgment for Ohio Security Insurance Company and entering judgment against Zain Beauty Supply, holding that Zain failed to satisfy contractual conditions precedent to payment under the insurance policy, and reasoning that the policy required actual repair or replacement before recovery of replacement‑cost benefits and further permitted an actual‑cash‑value claim only if affirmatively submitted, neither of which Zain supported with record evidence, leaving no genuine dispute of material fact.) https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-01679-17-8-cv
Flood Insurance
Potter-Martino v. American Bankers Ins. Co. of Fla., No. 8:26-cv-00508-WFJ-AEP (M.D. Fla., Apr. 13, 2026 (Jung, J.)) (granting American Bankers Insurance Company of Florida’s motion to dismiss with prejudice, holding that the plaintiff’s SFIP breach‑of‑contract claim was time‑barred under the one‑year statute of limitations in 42 U.S.C. § 4072, and reasoning that although the plaintiff filed within one year in state court, exclusive federal jurisdiction applies and filing in state court does not toll the limitations period, so removal to federal court after the one‑year deadline rendered the action untimely.) https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2026-00508-16-8-cv
General Liability Insurance
AXA XL Ins. Co. UK Limited, et al. v. McPherson, No. 8:25-cv-202-WFJ-AAS(M.D. Fla., Apr. 16, 2026 (Arnold Sansone, J.)) (granting in part and denying in part AXA XL’s motion to compel, ordering Delta to produce any existing non‑privileged communications related to a fall or fall investigation concerning Virginia McPherson and, if such investigatory materials once existed but no longer do, to supplement its interrogatory response accordingly, and reasoning that Delta’s objections to the document request were largely unfounded because the requests were reasonably interpreted and relevant, but it declined to compel a different interrogatory response absent a clear showing it was evasive or incomplete, instead requiring supplementation only if documents were destroyed or withheld.) https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00202-142-8-cv
Long-Term Disability Insurance
Dunham-Zemberi v. Lincoln Life Assurance Co. of Boston, No. 22-13316 (11th Cir., Apr. 14, 2026 (Newsom, Branch, and Luck, C.J.)) (affirming the district court’s judgment in favor of Lincoln Life Assurance Company, holding that Lincoln was not de novo wrong in terminating Bryce Dunham-Zemberi’s long‑term disability benefits under ERISA because he failed to submit required proof of continued disability, and reasoning that the plan expressly required objective medical evidence showing an inability to perform a material job duty (lifting up to fifty pounds), and the medical record instead demonstrated normal post‑surgical healing, full strength, and no medically supported lifting restrictions, leaving Dunham-Zemberi unable to meet his burden under the plan.) https://media.ca11.uscourts.gov/opinions/unpub/files/202213316.pdf
The Fine Print:
The cases discussed are not a comprehensive list of all Florida decisions from this week. SLC may omit some, including PCAs and procedural rulings unrelated to coverage. SLC also excludes any cases in which I am or have been personally involved. These summaries are provided solely for informational purposes and do not constitute legal advice or create an attorney-client relationship. Any opinions expressed are my own and are not intended as legal guidance for any specific situation.