Progressive American Insurance Co. v. Hillsborough Insurance Recovery Center, LLC & Progressive American Insurance Co. v. Shazam Auto Glass, LLC
Progressive appealed county court orders denying its motions to compel appraisal of windshield repair/replacement claims and striking the mandatory component of the policies' appraisal provisions. The Second District reversed, holding that the policies impose no good-faith-negotiation precondition to invoking appraisal, that courts may not create an 'economically unreasonable' doctrine to excuse small-dollar claims from contractual appraisal, and that the appraisal provision does not violate the public policy of section 627.428.
Key facts
- Progressive American Insurance Company appealed county court orders denying its motions to compel appraisal of windshield repair and replacement claims against Hillsborough Insurance Recovery Center, LLC and Shazam Auto Glass, LLC.
- The trial court struck the mandatory appraisal provisions from Progressive's insurance policies and refused to compel appraisal, reasoning that good-faith negotiation was a prerequisite to appraisal and that appraisal would be economically unreasonable given the small dollar amounts in dispute.
- +2 more key facts with a free trial
Why it matters
This decision reinforces the Second District's line of windshield-appraisal cases (Glassmetics, SHL Enterprises) and forecloses trial-court efforts to sidestep mandatory appraisal in low-value AOB claims via good-faith… — 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.