American Coastal Insurance Co. v. Ironwood, Inc.
A condominium association invoked appraisal on a later-filed windows-and-doors claim from Hurricane Irma before the insurer completed its coverage determination, and the trial court compelled appraisal based solely on the pleadings. The Second DCA reversed, holding the trial court had to first resolve the genuine factual dispute over the insured's compliance with post-loss document obligations, and that the windows-and-doors claim was a 'supplemental claim' under the policy definition, so appraisal was premature until the insurer made a coverage determination after a reasonable opportunity to investigate.
Key facts
- American Coastal Insurance Co. and Ironwood, Inc., a condominium association, disputed coverage for windows-and-doors damage from Hurricane Irma after the insurer had already adjusted an earlier claim for the same hurricane.
- The condominium association invoked appraisal before the insurer completed its coverage determination and submitted post-loss documentation requests; the trial court compelled appraisal based solely on the pleadings.
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Why it matters
Useful ammunition for property insurers resisting premature appraisal demands: it requires trial courts to hold an evidentiary hearing and actually resolve post-loss compliance disputes, not just review the pleadings… — full analysis with a trial
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