Security First Insurance Company v. Moreno
After a jury rejected Security First's prompt-notice defense and awarded the insureds damages on their Hurricane Irma claim, the Third DCA held that the insurer was entitled to a directed verdict on the first prong of the prompt-notice analysis because the insureds' notice came roughly two and a half years after they discovered worsening water stains. The court reversed the final judgment and remanded for a new trial limited to the second prong — whether the untimely notice prejudiced the insurer.
Key facts
- Security First Insurance Company issued a homeowner's policy to the Morenos covering their Florida residence; the insureds discovered water stains approximately two months after Hurricane Irma and observed the staining worsen with each subsequent windy storm.
- The Morenos did not report the loss to Security First until roughly two and a half years after discovering the worsening water damage, citing personal issues as the reason for the delay.
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Why it matters
Insurer-side counsel gains a Third DCA data point for taking the promptness question away from the jury where the insured admits awareness of ongoing, worsening damage and offers only personal-hardship excuses for a… — full analysis with a trial
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