State Farm Florida Insurance Co. v. Sanders
State Farm sought certiorari after the trial court allowed the insureds' public adjuster — their contractual agent, who had inspected the loss, reported the claim, prepared the damage estimate, and held a 10% contingency interest in the recovery — to serve as their 'disinterested' appraiser under the policy's appraisal clause. The Third DCA granted the writ and quashed the order, holding as a matter of law that a fiduciary such as a public adjuster in an agent-principal relationship with the insureds cannot serve as a disinterested appraiser.
Key facts
- State Farm sought certiorari after a trial court allowed the insureds' public adjuster—who had inspected the loss, reported the claim, prepared the damage estimate, and held a 10% contingency interest in recovery—to serve as their 'disinterested' appraiser under the insurance policy's appraisal clause.
- The public adjuster was a contractual agent of the insureds in an agent-principal fiduciary relationship.
- +2 more key facts with a free trial
Why it matters
This is a reusable, bright-line rule for first-party property practitioners: insurers can now cite Sanders to disqualify an insured's public adjuster as a 'disinterested' appraiser whenever the adjuster is a contractual… — full analysis with a trial
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