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2nd DCAAugust 14, 2026Affirmed⚡ Circuit Split Resolved

Universal Property & Casualty Insurance Company v. William Bell and Denise Bell

Case No. 2025-1483

The Second District affirmed per curiam, reaffirming its holding in Buis that section 627.70152, Florida Statutes, does not apply retroactively to property insurance policies entered into before the statute's July 1, 2021 effective date because the Legislature did not clearly express an intent for retroactive application. The court aligned itself with the First, Fifth, and Sixth Districts and again certified conflict with the Third and Fourth Districts. The issue remains pending before the Florida Supreme Court on review of Hughes v. Universal Property & Casualty Insurance.

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