Healthy Food Experts, LLC v. AmGuard Insurance Company
The Fourth DCA reversed dismissal of a first-party statutory bad faith action under section 624.155. It held that the trial court misapplied Fridman: an underlying breach-of-contract verdict is a binding prerequisite to a bad faith claim, not a bar to it, and it does not cap the insured's recovery of extra-contractual consequential damages. The court also clarified that Fridman's UM/UIM excess-judgment principles do not carry over to first-party property insurance.
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