First-Party Commercial Property Insurance
Healthy Food Experts, LLC v. Amguard Ins. Co., 4D2025-0181 (4th Dist. of Fla., June 10, 2026 – Gerber, J. (Ciklin and Lott, JJ. concurring)). (reversing the dismissal of the insured’s bad faith claim, holding that a prior breach-of-contract verdict and payment of that judgment do not bar a subsequent first-party bad faith action seeking extra-contractual damages, and reasoning that Fridman was misapplied—while the underlying verdict fixes contractual damages and prevents relitigation of those amounts, it serves as a prerequisite (not a bar) to a bad faith claim, which may still proceed to recover distinct extra-contractual damages caused by the insurer’s alleged misconduct). https://flcourts-media.flcourts.gov/content/download/2489874/opinion/Opinion_2025-0181.pdf
Auto Insurance
- GoAuto Ins. Co. v. 2B Claim Services, Inc., 24-13643 (11th Cir., June 8, 2026- Hull, CJ.) (affirming
summary judgment for the claims adjuster (2B), holding that the adjuster was not liable for the insurer’s excess settlement because it owed no duty to provide legal advice about bad-faith exposure and did not cause the insurer’s losses, and reasoning that the insurer’s own decision not to timely deliver settlement checks—despite knowing the deadline—was the proximate cause of its damages, and advising on bad-faith liability would constitute legal judgment outside the scope of a claims adjuster’s duties). https://media.ca11.uscourts.gov/opinions/unpub/files/202413643.pdf - Hinson v. Progressive American Ins. Co., 8:23-cv-1766-SPF(M.D. of Fla., June 11, 2026- Flynn, J.) (denying the insurer’s renewed motion for judgment as a matter of law or new trial and granted the plaintiff’s entitlement to attorney’s fees and costs, upholding the jury’s bad-faith verdict against the insurer, and reasoning that sufficient evidence supported the jury’s finding of bad faith—particularly the insurer’s failure to diligently pursue settlement opportunities before a demand expired—and that, as the insured’s assignee who prevailed, the plaintiff was entitled to fees under Florida Statute § 627.428, which applied despite its repeal because it could not be applied retroactively).
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2023-01766-154-8-cv
Business Auto Insurance
Prime Ins. Co., Inc. v. Medicab Transportation, LLC, et al., 2:24-cv-421-SPC-KRH (M.D. of Fla., June 8, 2026- Polster Chappel, J.) (granting summary judgment largely in favor of the insurers, holding that a prior Utah default declaratory judgment reforming the policy and finding no coverage precluded most of the insureds’ claims under collateral estoppel, and reasoning that the Utah judgment—entered after proper notice and opportunity to litigate—conclusively established no coverage or duty to defend, barring relitigation of those issues, though limited misrepresentation claims survived where they concerned distinct statements not decided in the prior action). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-00421-195-2-cv
Surplus Lines Property Insurance
- Hess v. Sutton Specialty Ins. Co., 2:24-cv-00514-JES-DNF (M.D. of Fla., June 9, 2026- Steele, J.) (granting in part the plaintiff’s motion for reconsideration, holding that the repeal of Florida’s surplus-lines attorney’s-fee statute could not be applied retroactively to eliminate the insured’s preexisting right to fees, and therefore the plaintiff was entitled to attorney’s fees after prevailing, and reasoning that the statutory fee right is a substantive, vested right tied to the insurance contract, so retroactive application of the repeal would improperly impair that right, and that an insured who obtains a favorable judgment or its equivalent after an insurer’s incorrect denial of benefits is entitled to fees regardless of the insurer’s good faith). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-00514-47-2-cv
- Sunlight Lands, LLC v. Westchester Surplus Lines Ins. Co., 2:24-cv-00267-JES-KCD (M.D. of Fla., June 10, 2026- Steele, J.) (denying the insured’s motion to confirm the appraisal award and for partial summary judgment, holding that confirmation was premature because unresolved coverage defenses remained at issue, and reasoning that while appraisal determines only the amount of loss, coverage issues—such as alleged policy violations or misrepresentations—must be resolved by the court through further proceedings, and the insurer’s payment of the appraisal award did not automatically waive those defenses or entitle the insured to judgment). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-00267-88-2-cv
Flood Insurance
- Flowers v. Wright National Flood Ins., 2:26-cv-633-JES-KRH (M.D. of Fla., June 10, 2026- Steele, J.) (granting the insurer’s motion to dismiss, holding that the plaintiff’s flood insurance claim was time-barred because it was not filed within the one-year limitations period required under the National Flood Insurance Act after the insurer’s partial denial, and reasoning that 42 U.S.C. § 4072 strictly requires suit to be filed within one year of the written denial, and because the plaintiff filed more than one year after the December 22, 2024 denial notice, the action was untimely and had to be dismissed). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2026-00633-20-2-cv
- Karlzen v. Selective Ins. Co. of the Southeast, 8:25-cv-3297-KKM-SPF (M.D. of Fla., June 12, 2026 -Kimball Mizelle, J.) (granting the insurer’s motion to dismiss and dismissed the complaint with prejudice, holding that the plaintiffs’ flood insurance claim was time-barred under the National Flood Insurance Act, and reasoning that the insurer’s written denial letter constituted a “notice of partial disallowance” that triggered the statute of limitations, and because the plaintiffs filed suit more than one year after the letter was mailed, their claims were untimely regardless of objections to the sufficiency of the denial notice). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-03297-35-8-cv
Procedural- Liability Insurance
Renaissance Specialty Ins., LLC v. Landrum, et al., 5:24-cv-00392-WGY-PRL (M.D. of Fla., June 11, 2026 -Lammens, J.) (denying the defendants’ motion to compel without prejudice, holding that the motion was procedurally deficient because the parties failed to meaningfully comply with the Middle District’s meet-and-confer requirements, and reasoning that the parties’ communications—limited to letters and emails—did not constitute the required good-faith, direct conference to resolve discovery disputes, and that proper conferral and more targeted motions were necessary before judicial intervention). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2024-00392-146-5-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.