Flood Insurance
Gaston v. Allstate Ins. Co., 8:25-cv-3421-KKM-NHA (M.D. Fla., June 26, 2026 – Kimball Mizelle, J.) (granting Allstate’s motion to dismiss and dismissing the insured’s flood-insurance breach-of-contract action with prejudice as barred by the National Flood Insurance Act’s one-year statute of limitations, and reasoning that Allstate’s December 12, 2024 letter stating it could not provide additional coverage for part of the claim was an objective “notice of disallowance” that triggered the limitations period, and later denial letters did not restart or extend that deadline, making the complaint filed on December 15, 2025 untimely by three days). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-03421-28-8-cv
General Liability Insurance
Atl. Cas. Ins. Co. v. Atl. S. Metals, LLC, 8:25-cv-3029-CEH-NHA (M.D. Fla., June 22, 2026 – Edwards Honeywell, J.) (granting Atlantic Casualty Insurance Company’s motion for final default judgment and declaring that it has no duty to defend or indemnify Atlantic Southern Metals, LLC in the underlying state-court construction lawsuit, and reasoning that the undisputed allegations established that Atlantic Southern Metals materially breached the policy’s cooperation clause by failing to provide notice of the lawsuit, failing to forward legal papers, and failing to respond despite the insurer’s extensive good-faith efforts to contact it, which substantially prejudiced the insurer’s ability to investigate and defend the claim). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-03029-14-8-cv
Property Insurance
Master Dry Out, Inc., a/a/o Abijana v. State Farm Florida Ins. Co., 2D2024-2205 (2nd Dist. of Fla., June 26, 2026- LaRose, J. (Rothstein-Youakim and Atkinson, JJ. concurring)) (affirming the denial of Master Dry Out’s motion for attorney’s fees, holding that its pretrial settlement with State Farm did not constitute a “judgment obtained” under section 627.7152(10)(a), Florida Statutes, and reasoning that the statute ties fee entitlement to damages recovered through a “judgment obtained,” and because the parties merely settled disputed claims with no admission of liability and dismissed the lawsuit, the settlement proceeds were a contractual compromise rather than damages awarded in a judgment). https://flcourts-media.flcourts.gov/content/download/2490550/opinion/Opinion_2024-2205.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.