Universal Insurance Company of North America v. Sunset 102 Office Park Condominium Association, Inc.
Universal appealed a $884,371.90 judgment for its insured following a Hurricane Irma property damage jury trial. The Third DCA affirmed, holding the trial court did not abuse its discretion in denying eleventh-hour leave to add a 'wet rot' exclusion defense, in denying an adverse-inference spoliation instruction where the insurer inspected four times and never sought reinspection before roof replacement, and in denying a mistrial; it also approved the concurrent cause instruction absent an anti-concurrent cause provision.
Key facts
- Universal Insurance Company appealed an $884,371.90 jury verdict in favor of its insured, Sunset 102 Office Park Condominium Association, Inc., following a Hurricane Irma property damage trial.
- Universal sought to add a 'wet rot' exclusion defense two business days before trial, requested a spoliation adverse-inference instruction based on the insured's roof replacement, and objected to the concurrent cause jury instruction.
- +2 more key facts with a free trial
Why it matters
The opinion's most transferable holding is its sharp rebuke of generic 'predicate' objections: counsel who use shorthand objections to comply with a no-speaking-objection rule risk complete waiver of substantive grounds… — 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.