Property Insurance
- AIG Property Casualty Co., as subrogee of Jeffrey McMillin v. Eco Marine Solutions, LLC, et al., 2:24-cv-722-SPC-NPM (US Middle District of Florida, Jan 7, 2026 – Judge Polster Chappell) (granting summary judgment for Eco Marine and Custom Electrical and finding that the Florida Building Code in effect at the time the dock permit was applied for (the Sixth Edition) did not require ground-fault protection on circuit breakers for single-family residential docks, so no breach of contract, warranty, or statutory violation occurred, and reasoning that because no code violation took place, AIG’s claims—including those under Fla. Stat. § 553.84—fail as a matter of law.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-00722-63-2-cv
Security First Ins. Co. v. Michael Moreno, et al., 3D24-1968 (Florida 3rd DCA, Jan 7, 2026 – Judge Scales) (reversing the trial court’s judgment and holding that the Morenos’ notice of their Hurricane Irma loss—given more than two years after discovering water damage—was untimely as a matter of law under the policy’s “prompt notice” requirement, and reasoning that the undisputed evidence showed the insureds knew of the damage shortly after the storm and delayed reporting without justification, requiring a new trial solely on whether the insurer was prejudiced by the late notice.)
https://flcourts-media.flcourts.gov/content/download/2483374/opinion/Opinion_2024-1968.pdf
Procedural – Specialty Insurance- Watercraft
- Procedural – Specialty Insurance- Watercraft
Accelerant Specialty Ins. Co. and Texas Ins. Co. v. Eric Small, 8:25-cv-425-KKM-AAS (US Middle District of Florida, Jan 6, 2026 – Judge Kimball Mizelle) (granting, in part, the insurers’ Rule 11 motion and finding that Small’s counsel made frivolous and misleading representations regarding service of process, subject‐matter jurisdiction, and entitlement to attorney’s fees, and holding that these arguments lacked any legal or factual basis, and ordering counsel (and his firm) to submit a fee award for preparation of the motion—imposing sanctions to deter such conduct.)
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00425-49-8-cv
Procedural – Auto Insurance
- Kenneth Healy, et al., v. Geico General Ins. Co., 5:25-cv-178-JSM-PRL (US Middle District of Florida, Jan 9, 2026 – Judge Lammens) (denying without prejudice GEICO’s motion to compel non-party production from Jonathan Thomson/Morgan & Morgan, finding the subpoena unenforceable under Rule 45 and reasoning that the subpoena imposed an undue burden by setting a compliance deadline that preceded service; thus, failing to allow a reasonable time to comply but granting GEICO leave to reissue a properly timed subpoena.)https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00178-21-5-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.