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4th DCAJune 4, 2025Reversed

Universal Property & Casualty Insurance Company v. West Naze

Case No. 4D2024-0098

The Fourth DCA reversed a breach-of-contract judgment against a property insurer after the trial court repeatedly admitted claims-handling evidence — including the insurer's delay in assigning an adjuster and internal communications — despite the insured having pleaded only breach of contract and no bad faith. The case is remanded for new trial.

Key facts

  • The insured reported water damage to his residential property on December 10, 2020; the insurer sent a field adjuster within days and then issued written document requests in late December 2020 and again on February 19, 2021.
  • The insured filed a complaint in Broward County Circuit Court alleging only breach of the insurance contract; no bad faith, extra-contractual claim, or claim of wrongdoing was pleaded.
  • +2 more key facts with a free trial

Holdings

  • Claims-handling evidence is irrelevant and inadmissible in a breach-of-contract action where no bad faith claim has been pleaded.
  • +1 more holding with a free trial
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