Lemon et al v. Hartford Ins. Co. of the Midwest, 2:23-cv-01140-JLB-NPM (U.S. District Court Middle District of Florida Fort Myers Division, July 2, 2025 – Judge Badalamenti)

Granting in part and denied in part Hartford Insurance’s motion for summary judgment, ruling that the plaintiffs, Michael and Daryl Lemon, are limited to recovering actual cash value (ACV) under their policy and not entitled to replacement cost value (RCV), matching costs, pre-existing damage, or Ordinance or Law-related expenses, because they had not incurred those costs prior to filing suit (see Trinidad v. Fla. Peninsula Ins. Co., 121 So. 3d 433, 438 (Fla. 2013); Vazquez v. Citizens Prop. Ins. Corp., 304 So. 3d 1280, 1285 (Fla. 3d DCA 2020)).
https://ecf.flmd.uscourts.gov/cgi-bin/show_public_doc?2023-01140-67-2-cv