Citizens Property Insurance Corp. v. Manor House, LLC
Insureds of nine hurricane-damaged apartment buildings sued Citizens for breach of contract, seeking roughly $2.5 million in lost rental income as extra-contractual consequential damages caused by Citizens' alleged delay in adjusting and paying the claim. The Florida Supreme Court answered the Fifth District's certified question in the negative, holding that extra-contractual, consequential damages are not recoverable in a first-party breach of insurance contract action because the amount due is fixed by the policy's express terms. Because Citizens is statutorily immune from first-party bad faith claims, no extra-contractual recovery was available at all.
Key facts
- Manor House, LLC and other insureds of nine hurricane-damaged apartment buildings sued Citizens Property Insurance Corp. for breach of contract, claiming approximately $2.5 million in lost rental income as consequential damages caused by Citizens' alleged delay in adjusting and paying their insurance claims.
- The trial court permitted the insureds to pursue extra-contractual consequential damages by attempting to prove the parties contemplated such damages beyond the policy's express terms.
- +2 more key facts with a free trial
Why it matters
This is a landmark insurance-coverage ruling that closes the door on consequential-damage claims (lost rents, lost profits, delay damages) dressed up as breach of contract in first-party property cases, channeling all… — full analysis with a trial
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