Citizens Property Insurance Corp. v. Salazar
Citizens paid the actual cash value of a water-damage claim; the homeowner sued for underpayment and, over Citizens' motion in limine, was allowed to prove damages with her public adjuster's replacement-cost estimate that included projected matching costs. The Third DCA held that under section 627.7011(3)(a) and the policy, the correct measure of damages until repairs are performed is actual cash value (excluding projected matching costs), so admitting the replacement-cost estimate was error, and remanded for a new trial because the failure of proof was caused by judicial error.
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