Certain Underwriters at Lloyd's v. Lago Grande 5-D Condominium Ass'n, Inc.
After Hurricane Irma, the condominium association accepted (without responding to) the insurer's coverage determination letter and $137,619.38 payment, then sued ten months later alleging underpayment and moved to compel appraisal. The Third DCA reversed the order compelling appraisal, holding that because the association never provided a counter-estimate, expressed disagreement, or demanded additional payment, there was no 'meaningful exchange of information' establishing a genuine disagreement over the amount of loss, so appraisal was premature.
Key facts
- Condominium association accepted an insurer's $137,619.38 hurricane damage payment and coverage determination letter without objection, counter-estimate, or expressed disagreement.
- Ten months after accepting the payment, the association filed suit alleging underpayment and moved to compel appraisal of the property damage.
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Why it matters
This decision reinforces and extends the Third DCA's Romay/Redlhammer line for insurers defending first-party property claims, giving them a strong basis to resist premature appraisal where the insured simply accepts… — full analysis with a trial
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