Express Damage Restoration, LLC v. Citizens Property Insurance Corp.
An AOB assignee water-mitigation vendor sued Citizens for a declaration that the HO-3 policy's appraisal provision did not reach a dispute over the necessity and reasonableness of post-loss water mitigation charges. The Third DCA affirmed summary judgment for Citizens, holding the appraisal condition in Section I unambiguously covers disputes over 'Reasonable Repairs' performed to protect against further damage, because the appraisal clause is a condition applicable to all Section I coverages.
Key facts
- Express Damage Restoration, an AOB assignee water-mitigation vendor, sued Citizens Property Insurance Corp. seeking a declaration that the HO-3 policy's appraisal provision did not apply to disputes over the necessity and reasonableness of post-loss water mitigation charges.
- The trial court granted summary judgment in favor of Citizens, finding that the appraisal condition applied to the mitigation services dispute.
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Why it matters
Property insurers and AOB vendors litigate frequently over whether appraisal reaches disputes about the reasonableness of emergency water-mitigation invoices; this opinion gives insurers a published Third DCA holding… — full analysis with a trial
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