Government Employees Insurance Co. v. Glassco Inc.
Answering two questions certified by the Eleventh Circuit, the Florida Supreme Court held that an insurer is not a "customer" under the Florida Motor Vehicle Repair Act and therefore has no private cause of action under section 559.921(1) when a repair shop fails to provide a written repair estimate. The Court also held that the alleged Repair Act disclosure violations do not void a repair invoice for completed windshield work or preclude the shop from being paid by the insurer, and it declared the reasoning of Osteen v. Morris obsolete in light of post-1993 amendments to the statute.
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