Procedure
- Great Lakes Ins. SE v. Crabtree and Crabtree,23-12020(11th Cir., May 19, 2026 (Newsom, C.J.)) (affirming the district court’s order granting summary judgment to the Crabtrees, holding that under Rule 41(a)(1)(B) Great Lakes’s second voluntary dismissal of the same claim operated as an adjudication on the merits (i.e., a dismissal with prejudice), thereby barring re-litigation).
https://media.ca11.uscourts.gov/opinions/pub/files/202312020.pdf - Northfield Ins. Co. v. North Brook Industries, Inc., 24-13333 (11th Cir., May 22, 2026 (Tjoflat, C.J.)) (dismissing Northfield’s appeal for lack of jurisdiction, holding that the district court’s order—partially granting North Brook’s motion to dismiss on the duty-to-defend issue while leaving the duty-to-indemnify claim pending—was neither a final decision under 28 U.S.C. § 1291 nor an appealable interlocutory order under § 1292(a)(1) because it did not grant substantive relief, direct action, or have the practical effect of an injunction)). https://media.ca11.uscourts.gov/opinions/pub/files/202413333.pdf
Property Insurance
Baytree, Condo. Section Eight, Inc. v. Clear Blue Specialty Ins. Co.,24-10889 (11th Cir, May 21, 2026 (Luck, C.J.)) (affirming the district court’s denial of Baytree’s summary judgment motion on appraisal during the first phase of the case and reversing summary judgment for Clear Blue during the second phase, holding that appraisal was unavailable where a live coverage dispute remained regarding compliance with the notice provision and no waiver occurred, but summary judgment was inappropriate because a genuine jury issue existed as to whether the insured’s late notice prejudiced the insurer in investigating the loss). https://media.ca11.uscourts.gov/opinions/unpub/files/202410889.pdf
Maritime Insurance
Accelerant Specialty Ins. Co., et al. v. Zubigaray, 23-cv-23401-ALTMAN (S.D. Fla., May. 18, 2026 (Altman, J.)) (granting Plaintiffs’ motion for summary judgment and declaring the policy void ab initio, holding that the insured’s breach of the survey-compliance warranty and material misrepresentations on the application independently voided coverage under both New York law and the federal maritime doctrine of uberrimae fidei [utmost good faith]). https://www.govinfo.gov/content/pkg/USCOURTS-flsd-1_24-cv-23401/pdf/USCOURTS-flsd-1_24-cv-23401-0.pdf
Flood Insurance
Sirianni v. American Strategic Ins. Co., 2:26-cv-76-SPC-DNF (M.D. Fla., May. 20, 2026 (Polster Chappell, J.)) (dismissing Plaintiff’s complaint without prejudice for lack of subject-matter jurisdiction because the claim was unripe, as no written denial of the Standard Flood Insurance Policy claim had been issued). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2026-00076-27-2-cv
Homeowners Insurance
Buchheit, Jr. v. The Cincinnati Ins. Co., 2:26-cv-171-SPC-KRH(M.D. Fla., May. 20, 2026 (Polster Chappell, J.)) (granting Defendant’s motion to dismiss, holding that Plaintiff’s declaratory‑relief and breach‑of‑contract claims were unripe because the insurer had not issued a final denial of coverage and Plaintiff could not compel appraisal because appraisal is purely contractual and the policy required mutual consent). https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2026-00171-27-2-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.