Citizens Property Insurance Corporation v. Maria Blanco Suarez
Citizens served $100 nominal proposals for settlement based on the insureds' two-year-late notice of a Hurricane Irma claim and failure to produce requested documents, later won summary judgment on those same grounds, and was denied fees on a good-faith challenge. The Third DCA reversed, holding the trial court abused its discretion because the pre-suit coverage defenses gave Citizens a reasonable foundation for a nominal offer, and directed entry of a fee award under section 768.79.
Key facts
- Citizens Property Insurance Corporation served a $100 nominal settlement proposal on insureds Maria Blanco Suarez based on their two-year-late notice of a Hurricane Irma claim and failure to produce requested documents.
- Citizens later moved for and obtained summary judgment on the same grounds—late notice and failure to produce documents—but the trial court denied Citizens' request for attorney's fees under section 768.79 based on a good-faith challenge.
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Why it matters
This opinion gives insurers and other defendants concrete support for nominal proposals for settlement served early, before discovery, where a dispositive defense is already apparent from the pre-suit record. It… — full analysis with a trial
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