Universal Insurance Company of North America v. Sunset 102 Office Park Condominium Association, Inc.
The Third DCA affirmed a Miami-Dade Circuit Court judgment against a property insurer in a dispute involving a condominium association. The per curiam citation opinion addresses three distinct grounds: failure to preserve an argument for appellate review, the standard for awarding an attorney fee multiplier under the second prong of Joyce v. Federated National Insurance Co., and the abuse of discretion standard governing a trial court's multiplier award where record evidence supports the ruling.
Key facts
- Universal Insurance Company of North America appealed a final judgment entered by Miami-Dade Circuit Court Judge Tanya Brinkley in a case originally filed in 2018 (lower tribunal no. 18-42359-CA-01).
- The appellee, Sunset 102 Office Park Condominium Association, Inc., was the prevailing party below in an insurance coverage dispute.
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Holdings
- To preserve an issue for appellate review, the specific legal argument or ground must be raised before the lower tribunal; failure to do so forfeits review.
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