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First National Bank of Lake Park, N.A. v. Attorneys' Title Insurance Fund, Inc.

Citations: 620 So. 2d 263; 1993 Fla. App. LEXIS 6918Docket: No. 92-2321

Court: District Court of Appeal of Florida; June 30, 1993; Florida; State Appellate Court

Narrative Opinion Summary

An appeal was made regarding a summary final judgment that denied coverage under a title insurance policy. The complaint included two counts for breach of contract and one count for negligent misrepresentation. The judgment affirmatively denied the tort claim for negligent misrepresentation, referencing precedents such as AFM Corp. v. Southern Bell Tel. Co. and First American Title Ins. Co. However, the trial court's dismissal of the breach of contract claims was based on the assertion that the title insurance contract explicitly excluded the matters raised by the plaintiff. The appellate court found that there were genuine material issues of fact, particularly regarding the ownership of lot E, which warranted a reversal of the summary judgment. The case is reversed and remanded for further proceedings. Judges Hersey, Gunther, and Stone concurred with the decision.

Legal Issues Addressed

Denial of Tort Claims in Insurance Litigation

Application: The judgment affirmed the denial of the negligent misrepresentation claim, aligning with legal precedents that limit such tort claims under similar circumstances.

Reasoning: The judgment affirmatively denied the tort claim for negligent misrepresentation, referencing precedents such as AFM Corp. v. Southern Bell Tel. Co. and First American Title Ins. Co.

Exclusion Clauses in Title Insurance Contracts

Application: The trial court's dismissal of the breach of contract claims was based on the contract's explicit exclusion of matters raised by the plaintiff.

Reasoning: The trial court's dismissal of the breach of contract claims was based on the assertion that the title insurance contract explicitly excluded the matters raised by the plaintiff.

Summary Judgment in Insurance Disputes

Application: The appellate court reversed the summary judgment, finding genuine material issues of fact that were not suitable for summary judgment resolution.

Reasoning: The appellate court found that there were genuine material issues of fact, particularly regarding the ownership of lot E, which warranted a reversal of the summary judgment.