Worldwide Door Components, Inc. v. Zurich American Insurance Co.
Insureds sued Zurich for statutory bad faith after an appraisal award came in nearly 22 times the insurer's estimate. The court held that Fla. Stat. § 624.1551's 'adverse adjudication' prerequisite applies only to bad-faith claims brought under § 624.155(1)(b), not to claims pleaded under § 624.155(1)(a) and § 626.9541, so the suit was not premature; the court also found the complaint and attached Civil Remedy Notices adequately pleaded bad faith and damages.
Key facts
- Worldwide Door Components, an insured, sued Zurich American Insurance for statutory bad faith after an appraisal award determined the insurer owed nearly 22 times its initial estimate for a property damage claim.
- Zurich moved to dismiss, arguing the bad-faith claim was premature because Florida law requires an adverse adjudication and final judgment before suit can be filed.
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Why it matters
This is a practitioner-useful reading of Florida's 2022-era property insurance bad-faith reform: § 624.1551's adverse-adjudication condition is cabined to § 624.155(1)(b) claims, so pleading under § 624.155(1)(a)/§… — full analysis with a trial
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