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Health Insurance

Mendoza v. Aetna Life Ins. Co., 23-13674 (11th Cir., Mar. 19, 2026 (Lagoa, C.J., with Newsom, J. and Kidd, J. concurring)) (affirming in part and reversing in part the district court’s dismissal of Plaintiff’s Complaint, holding that Mendoza failed to plausibly allege that Aetna was the primary insurer, as she did not plead facts showing either that the father’s insurance plan lacked newborn coverage or that the coordination‑of‑benefits “birthday rule” made Aetna primary, but remanding to allow amendment, as readily knowable facts—such as the father’s birthday or the actual terms of his plan—could cure the pleading deficiencies if alleged in good faith.) https://media.ca11.uscourts.gov/opinions/unpub/files/202313674.pdf

Property Insurance

John Miller and Erica Miller v. Liberty Mutual Fire Ins. Co., 6:25-cv-502-JA-NWH (M.D. Fla., Mar. 19, 2026 (Antoon II, J.)) (granting Defendant’s motion for summary judgement, holding that Plaintiffs provided no timely, pre‑suit evidence disputing the insurer’s actual cash value estimate, and their only contrary evidence—a post‑suit expert report and a pre‑suit replacement‑cost proposal—could not establish a breach under Florida law.) https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2025-00502-32-6-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.