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Standard Guaranty Insurance Co. v. Furtado

Citations: 502 So. 2d 1004; 12 Fla. L. Weekly 580; 1987 Fla. App. LEXIS 6822Docket: No. 86-1222

Court: District Court of Appeal of Florida; February 18, 1987; Florida; State Appellate Court

Narrative Opinion Summary

The case involves an appeal concerning a declaratory relief judgment between an individual insured and Standard Guaranty Insurance Company. The insured applied for motorcycle insurance, which was later canceled by the insurer due to underwriting reasons. Despite receiving a cancellation notice, the insured relied on assurances from his insurance agent that the policy would remain in effect. Shortly after, the insured was involved in an accident, leading him to file a complaint for insurance coverage and damages. The trial court ruled in favor of the insured, citing the acceptance of premium payments as misleading. However, the appellate court reversed this decision, determining that the insured was adequately notified of the cancellation, and the late payment did not extend coverage. The appellate court emphasized the insured's responsibility to seek alternative insurance upon notice of cancellation. The ruling was supported by the concurrence of the Chief Judge and another judge, affirming that the insured was not covered by the insurer at the time of the accident.

Legal Issues Addressed

Duty to Seek Alternative Insurance

Application: The court held that the insured party had a duty to seek alternative insurance upon receiving a cancellation notice.

Reasoning: It was established that Furtado could have sought alternative insurance before the cancellation took effect.

Effect of Insurance Policy Cancellation Notice

Application: The appellate court found that a cancellation notice effectively terminated the insurance policy, regardless of subsequent premium payments.

Reasoning: Standard Guaranty contended that the trial court's ruling was erroneous, as Furtado had been properly notified of the cancellation prior to the accident, and the late payment did not extend coverage past the cancellation date.

Reliance on Insurance Agent's Assurance

Application: The court concluded that reliance on an insurance agent's assurance without formal policy endorsement does not reinstate canceled coverage.

Reasoning: Matthews informed Furtado that Standard Guaranty could not insure his motorcycle due to its size, yet also indicated that the policy would be honored as of the last cancellation date.