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.
Key facts
- GEICO, an insurer, challenged a windshield repair invoice from Glassco Inc., alleging the repair shop violated the Florida Motor Vehicle Repair Act by failing to provide a written repair estimate.
- The trial court and lower courts applied the Osteen v. Morris doctrine to void the repair invoice based on alleged Repair Act disclosure violations.
- +2 more key facts with a free trial
Why it matters
This decision effectively guts the widely cited Osteen line of DCA cases holding that Repair Act violations render a repair invoice unenforceable, removing a common defense in auto-repair collection suits. Insurers… — full analysis with a trial
Read the full opinion, holdings & search — free for 30 days
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision — in your hands.
- Search every tracked Florida decision in seconds
- Save, tag & file the cases that matter into your own library
- Read the full plain-English analysis and holdings
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.