Dri Force Restoration, Inc., a/a/o Andre Chow v. Citizens Property Insurance Corporation
The Third DCA affirmed summary judgment for Citizens, holding that debris removal performed in conjunction with reasonable emergency measures is part of those services and not a separately compensable charge under the policy's Debris Removal coverage. The court applied the plain, unambiguous policy language and followed the Fourth DCA's Certified Priority Restoration decision.
Key facts
- A Citizens-insured home sustained two separate water losses; Dri Force performed restoration services under an assignment of benefits.
- Dri Force's invoices each included a $134.46 charge for hauling debris alongside the water mitigation charges.
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Holdings
- Debris removal performed as an inherent part of water-mitigation/reasonable emergency measures services is encompassed within those services and does not qualify as a separate charge under…
Why it matters
This decision strengthens Citizens' and other insurers' position that AOB restoration vendors cannot circumvent the statutory/policy $3,000 reasonable-emergency-measures cap by recharacterizing incidental debris hauling… — full analysis with a trial
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