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Blakely v. First Protective Ins. Co.

Citation: 260 So. 3d 1200Docket: No. 3D18-1511

Court: District Court of Appeal of Florida; January 29, 2019; Florida; State Appellate Court

Narrative Opinion Summary

The case involves an appeal by Geraldine and Christopher Blakely against a non-final order requiring their participation in an appraisal process related to a first-party property insurance dispute with First Protective Insurance Company (FPIC). The appellate court reversed the trial court's order, acknowledging FPIC's partial confession of error, and emphasized the necessity of conducting an evidentiary hearing before initiating the appraisal process. The decision cited relevant case law, such as Universal Prop. Cas. Ins. Co. v. Abbott, underscoring the procedural requirement for an evidentiary hearing. The court remanded the case for further proceedings, mandating a properly noticed evidentiary hearing. Additionally, the court addressed the Blakelys' concerns regarding pending discovery motions, stating that they could petition for a writ of mandamus if timely rulings were not provided. The ruling delineates the role of mandamus in ensuring judicial processes are completed, although it cannot dictate the outcome of those processes.

Legal Issues Addressed

Remand for Further Proceedings with Proper Notice

Application: The case was remanded with instructions for further proceedings, highlighting the necessity for a properly noticed evidentiary hearing.

Reasoning: The court remanded the case for further proceedings, specifying the need for a properly noticed evidentiary hearing.

Requirement for Evidentiary Hearing Prior to Appraisal

Application: The appellate court determined that an evidentiary hearing is necessary before proceeding with an appraisal process in a property insurance dispute.

Reasoning: The court reversed the trial court's order, agreeing with FPIC's partial confession of error, and determined that an evidentiary hearing must occur before any appraisal is conducted.

Use of Mandamus in Ensuring Judicial Rulings

Application: The court clarified that while mandamus cannot dictate the substance of a judicial outcome, it can serve to ensure that a decision is rendered.

Reasoning: The document emphasizes that while mandamus cannot compel a specific judicial outcome, it can ensure that a ruling is made.