Flood Insurance
- Louis Azzilonna v. First Community Ins. Co., 2:24-cv-955 (U.S. Middle District of Florida, Dec 22, 2025 – Judge Polster Chappel) (granting First Community Insurance Company’s motion for summary judgment—treated as unopposed due to Plaintiff’s failure to respond—and finding that Louis Azzilonna’s action for additional flood insurance benefits must fail because he missed the condition precedent of timely submitting a proof of loss under the Standard Flood Insurance Policy—even accounting for FEMA’s deadline extension—and therefore is not entitled to further recovery.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-00955-36-2-cv
Homeowners Insurance
- Kenneth Erickson v. Evanston Ins. Co., 2:24-cv-30 (U.S. Middle District of Florida, Dec 23, 2025 – Judge Dudek) (granting Evanston Insurance Company’s motion for partial summary judgment and denying Plaintiff Kenneth Erickson’s motion, holding that the homeowner’s policy explicitly excludes flood and storm surge damage, enforces a $10,000 sublimit on covered water damage, and bars recovery for losses caused by both covered and excluded perils under its anti-concurrent-cause provision, and reasoning that Erickson’s “named-perils” policy requires the plaintiff to attribute loss to a covered peril, and because the damage involved excluded flood/storm-surge events mixed with covered perils, additional recovery beyond the sublimit was precluded.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-00030-64-2-cv
Security First Ins. Co. d/b/a Security First Florida v. Dominick Cincotta and Cochran Ins. Co. et al., 6D2024-0385 (Florida 6th DCA, Dec 23, 2025 – Judge Cohen) (reversing the trial court’s denial of Security First’s entitlement to attorney’s fees, concluding the Proposal for Settlement (PFS) was unambiguous when read as a whole and clearly applied only to claims against Security First—not Cochran—satisfying section 768.79 and Florida Rule of Civil Procedure 1.442 and reasoning that although one paragraph could suggest ambiguity in isolation, context and industry precedent require construing the entire PFS reasonably, demonstrating the ambiguity did not impair the offerees’ ability to make an informed decision.)
https://flcourts-media.flcourts.gov/content/download/2482951/opinion/Opinion_2024-0385.pdf
Property Insurance
- Phyllis Burzee v. American Traditions Ins. Co., 6D2023-4030 (Florida 6th DCA, Dec 23, 2025 – Judge Traveler) (reversing the trial court’s dismissal of Burzee’s lawsuit, holding that her suit was not premature because she complied with section 627.70152, which allowed filing after appraisal had lasted more than ninety days following notice of intent, and reasoning that the statute’s language controls over the policy terms, and unresolved issues—such as interest and attorney’s fees—meant the case should proceed.)
https://flcourts-media.flcourts.gov/content/download/2482928/opinion/Opinion_2023-4030.pdf
Auto Insurance
- Carmen Daniella Mora Sanchez, et al. v. State Farm Mutual Automotive Ins. Co., et al., 3:21-cv-372 (U.S. Middle District of Florida, Dec 22, 2025 – Judge Corrigan) (denying Plaintiffs’ December 3, 2025 motion for a “Time‑Sensitive Motion to Issue Corrective Supplemental Notice” and requested extension of the claims deadline, finding that the proposed revised claim form constituted a material alteration of the Settlement Agreement—which had been previously negotiated and incorporated—could not be unilaterally changed absent all parties’ written consent, and reasoning that such a substantive modification would undermine the bargained-for terms and finality of the settlement, which the Court had expressly retained jurisdiction to enforce, not amend.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2021-00372-211-3-cv
Shannon Stewart v. The Standard Fire Ins. Co., 5:25-cv-667 (U.S. Middle District of Florida, Dec 22, 2025 – Judge Polster Chappel) (granting the unopposed motion and dismissed Shannon Stewart’s bad-faith claim under § 624.155 (Count II) without prejudice, finding it premature in the context of her underinsured motorist claim, and holding that allowing the claim to proceed would violate Article III’s ripeness requirement, since the bad-faith claim depends on future contingent events that have not yet occurred.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00667-17-5-cv
Shannon Stewart v. The Standard Fire Ins. Co., 5:25-cv-667 (U.S. Middle District of Florida, Dec 22, 2025 – Judge Polster Chappel) (denying Shannon Stewart’s motion to remand, finding that federal diversity jurisdiction exists and abstention under the Colorado River doctrine is inapplicable because the state-court negligence action is neither parallel—due to different parties—nor involves the same substantive issues as the federal insurance coverage dispute, and reasoning that abstention requires substantially identical parties and claims, which are absent here, thus the federal court must proceed with the case.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00667-16-5-cv
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.