SARUP
v.
CITIZENS PROPERTY INSURANCE CORPORATION

Fla. 2d DCA | 2026-08-21
No. 2025-0953
Williams, J., Northcutt, J., Villanti, J., Khouzam, J.
2026 FL 10740 Florida District Court of Appeal, Second District (2026)

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Holding

A trial court's exclusion of an expert witness cannot be meaningfully reviewed on appeal when the appellate record is limited and does not provide sufficient information for review.


Headnotes

[1] An appellate court cannot meaningfully review a trial court's exclusion of expert testimony when the appellate record is limited and insufficient to permit such review.

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Facts & Procedural History

Ankur Sarup appealed a trial court decision that excluded his designated expert witness, who was his only causation expert in a property insurance dis…

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Opinion of the Court

DISTRICT COURT OF APPEAL F FLORIDA

SECOND DISTRICT

ANKUR SARUP, Appellant,

V.

CITIZENS PROPERTY INSURANCE CORPORATION, Appellee.

No. 2D2025-0953

August 21, 2026

Appeal from the Circuit Court for Pinellas County; Amy M. Williams, Judge.

Matthew K. Mullinax of Makris & Mullinax, P.A., Tampa, for Appellant.

David T. Burr, C. Ryan Jones, and Scot E. Samis, of Traub Lieberman Straus & Shrewsberry LLP, St. Petersburg, for Appellee.

PER CURIAM.

Although the trial court excluded the appellant's designated expert witness, who was his only causation expert, we are constrained to affirm because we cannot meaningfully review this issue on the limited appellate record before us. See Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979).

Affirmed.

NORTHCUTT, VILLANTI, and KHOUZAM, JJ., Concur.

Opinion subject to revision prior publication.

2


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