Sulzer v. American Integrity Insurance Co. of Florida
The Sixth DCA, following its decision in Hughes v. Universal Property & Casualty, held that section 627.70152's pre-suit notice requirement does not apply retroactively to insureds whose policies and losses predated the statute's 2021 enactment, and reversed the dismissal of the insureds' breach-of-policy suit. The court again certified direct conflict with the Fourth DCA's decision in Cole v. Universal Property & Casualty Insurance Co.
Key facts
- Insureds with homeowner policies issued and losses occurring before July 1, 2021 sued American Integrity Insurance for breach of policy.
- The trial court dismissed the lawsuit for failure to comply with section 627.70152's pre-suit notice requirement, which became effective in 2021.
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Why it matters
This decision deepens an existing and certified district conflict over whether the 2021 property-insurance pre-suit notice statute applies to pre-enactment policies and losses, an issue affecting a large volume of… — full analysis with a trial
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