Reed v. Citizens Property Insurance Corp.
Insureds sued Citizens for breach of contract while appraisal of their Hurricane Ian claim was still ongoing, then argued that Citizens' timely payment of the eventual appraisal award was a confession of judgment entitling them to fees and prejudgment interest. The Sixth District affirmed summary judgment for Citizens, holding the confession of judgment doctrine does not apply where there was no breakdown in the claims process and the suit was not a necessary catalyst for payment.
Key facts
- Insureds filed suit against Citizens Property Insurance Corp. for breach of contract while an appraisal of their Hurricane Ian insurance claim was still pending.
- Citizens timely accepted coverage, made payments, invoked appraisal, and paid the eventual appraisal award within the policy deadline.
- +2 more key facts with a free trial
Why it matters
This is the Sixth District's second decision in two weeks applying the 'race to the courthouse' limitation on the confession of judgment doctrine in first-party property cases, and it is directly useful to insurer-side… — full analysis with a trial
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