De Cardenas v. White Pine Insurance Company
Homeowners sued their insurer for hurricane water-intrusion damage; the trial court granted summary judgment for the insurer with only a conclusory statement that the homeowners' roofing expert's affidavit was insufficient to create a genuine issue of material fact. The Third District reversed, holding the order failed to satisfy amended rule 1.510(a)'s mandatory requirement that the court state its reasons on the record with enough specificity to guide the parties and permit appellate review.
Key facts
- Homeowners sued their insurer for hurricane water-intrusion damage to their property.
- The trial court granted summary judgment for the insurer, stating only that the homeowners' roofing expert's affidavit was insufficient to create a genuine issue of material fact.
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Why it matters
This is a practical, readily transferable holding: any summary judgment order entered on or after May 1, 2021 that recites only a conclusion about the absence of a genuine dispute is subject to reversal for… — full analysis with a trial
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