The Court reversed the trial court’s decision, ruling that Progressive American Insurance Company was not given the required 60 days’ notice before the bad faith action was filed, as mandated by section 624.155, Florida Statutes (2018). The Court emphasized that the statute’s notice requirement is a condition precedent to filing such actions, citing Talat Enters., Inc. v. Aetna Cas. & Sur. Co., 753 So. 2d 1278 (Fla. 2000) and Macola v. Gov’t Emps. Ins. Co., 953 So. 2d 451 (Fla. 2006).
https://supremecourt.flcourts.gov/content/download/2449200/opinion/Opinion_2023-2247.pdf