Leavitt Recreation & Hospitality Insurance, Inc. v. Florida Caverns R.V. Resort, LLC

In a negligent procurement of insurance case arising from Hurricane Michael, the First DCA reversed summary judgment entered against an RV park owner who alleged its insurance broker failed to obtain coverage for power stations damaged in the storm. The court held that a negligent procurement plaintiff is not required to produce an actual prior insurance policy expressly covering the disputed risk — the broker's own agent admission that the coverage was available under the very policy at issue sufficed to create genuine issues of material fact precluding summary judgment.

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