Universal Property & Casualty Insurance Co. v. Karmo
In a first-party homeowners claim arising from a water and sewage backup, a jury awarded $335,000 in replacement cost value (or $305,000 actual cash value) against Universal. The First DCA reversed the denial of Universal's motions for remittitur and new trial, holding the award was not supported by competent valuation evidence — the only admitted estimates valued the loss at about $79,680 (RCV) and $50,220 (ACV). Remanded for the trial court to determine the proper measure of damages and order remittitur consistent with the evidence.
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