Bad Faith:
- Lauren Woods v. Progressive American Ins. Co., 23-13407 (U.S. 11th Circuit Court of Appeals, Nov 17, 2025 – Judge Covington) (affirming the district court’s judgment for Progressive, holding that the exclusion of the underinsured motorist verdict and excess judgment as evidence in the bad faith trial was within the court’s discretion because those items were relevant only to damages—which the parties stipulated would be decided by the judge—and not to liability under Woods’s narrowed theory of bad faith. The court reasoned that evidentiary rulings are reviewed for abuse of discretion and found no error, emphasizing that an insurer may deny claims it in good faith believes are not owed and that the verdict and excess judgment would have confused the jury given Woods’s stipulation limiting bad faith to pretrial conduct.) https://media.ca11.uscourts.gov/opinions/pub/files/202313407.pdf
Liability Insurance:
- Parkland Chamber of Commerce, Inc., et al. v. Mount Vernon Fire Ins. Co., 0:24-cv-62400 (U.S. Southern District of Florida, Nov 18, 2025 – Judge Singhal) (granting Mount Vernon’s motion for summary judgment, holding that the insurer has no duty to defend because the policy’s discrimination exclusion unambiguously bars coverage for claims “arising out of” discrimination, which includes the tortious interference claim alleged to be racially and religiously motivated. The Court rejected arguments that the conduct exclusion created ambiguity, finding that the policy must be read as a whole and that “arising out of” is interpreted broadly under Florida law) https://www.govinfo.gov/content/pkg/USCOURTS-flsd-0_24-cv-62400/pdf/USCOURTS-flsd-0_24-cv-62400-0.pdf
Life Insurance:
- Cheriese D. Johnson v. Reliance Standard Life Ins. Co., et al., 23-13443 (U.S. 11th Circuit Court of Appeals, Nov 21, 2025 – Judge Grant with Judge Pryor dissenting) (reversing the district court’s granting of summary judgement for Reliance Standard Life Insurance Company, holding that Reliance’s denial of long-term disability benefits to Johnson and interpretation of the policy’s preexisting condition exclusion was both de novo wrong and unreasonable as it overlooked the distinction between receiving medical care for symptoms that are not inconsistent with a preexisting condition and receiving medical care for the preexisting condition itself. The court reasoned that interpreting “for” to include any treatment for symptoms later associated with a disease would arbitrarily expand the preexisting condition exclusion and is contrary to ERISA principles and the policy’s text.) https://media.ca11.uscourts.gov/opinions/pub/files/202313443.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.