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Sanchez v. Royal Palm Insurance Co.

Citations: 166 So. 3d 212; 2015 Fla. App. LEXIS 8991; 2015 WL 3645894Docket: No. 2D13-4852

Court: District Court of Appeal of Florida; June 12, 2015; Florida; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by homeowners against Royal Palm Insurance Company concerning a breach of contract dispute over home insurance coverage following sinkhole damage. The primary legal issue centers on whether Royal Palm was obligated to disburse benefits for subsurface repairs based on the homeowners' chosen method, which differed from the recommendation of Royal Palm’s engineering firm, AMEC-BCI. The trial court granted partial summary judgment in favor of Royal Palm, asserting that the insurance policy required adherence to the insurer's recommended repair method before benefits would be due. A subsequent trial on the issue of cosmetic damages resulted in a jury verdict favoring Royal Palm. Citing the case Roker v. Tower Hill Preferred Insurance Co. as controlling, the appellate court partially reversed the trial court's judgment and remanded for further proceedings, while affirming other aspects of the case. During the appellate process, a partial settlement was reached concerning the cosmetic damages claim, thus narrowing the appeal to the issue of subsurface repairs.

Legal Issues Addressed

Breach of Contract under Insurance Policy

Application: The court evaluated the obligations of an insurance company to disburse benefits based on their preferred repair methods versus the policyholders' chosen methods.

Reasoning: Royal Palm contended it had no obligation to disburse benefits for repairs until a contract aligned with BCI’s recommendations was executed.

Partial Settlement and Appeal Limitations

Application: The appeal was limited to the trial court's granting of partial summary judgment on subsurface repairs, following a settlement on cosmetic damages.

Reasoning: During the appeal, the Sanchezes noted a partial settlement regarding their cosmetic damages claim, limiting the appeal to whether the trial court properly granted the partial summary judgment concerning subsurface repairs.

Precedential Influence of Similar Cases

Application: The court referenced a similar case, Roker v. Tower Hill Preferred Insurance Co., as controlling, which influenced the partial reversal and remand for further proceedings.

Reasoning: The court noted significant parallels with the case Roker v. Tower Hill Preferred Insurance Co., which involved similar entities and arguments.

Summary Judgment Standards in Contract Disputes

Application: The trial court granted summary judgment based on the insurance company's interpretation of the contract, indicating no material factual dispute regarding repair methods.

Reasoning: The trial court sided with Royal Palm, granting summary judgment.