FLORIDA DRY SOLUTIONS LLC, A/A/O NELIDA RODGERS
v.
CITIZENS PROPERTY INSURANCE CORPORATION

Fla. 3d DCA | 2021-02-17
No. 21-0041
DiRaimondo, J., Hendon, J., Fernandez, J., Gordo, J.
305 So. 3d 752 Florida District Court of Appeal, Third District (2021) Positive Treatment
Cited by 14 cases

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

Once an insurer proves an exclusion in an insurance policy applies, the burden shifts to the insured to demonstrate an exception to that exclusion.


Headnotes

[1] Once an insurer proves that an exclusion in an insurance policy applies to a claim, the burden of proof shifts to the insured to demonstrate that an exception to the excl…

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Key Quotes

“once an exclusion has been proven by the insurer, the burden once again is placed on the insured to demonstrate the exception to the exclusion”

Citation to E. Fla. Hauling, Inc. v. Lexington Ins. Co., 913 So. 2d 673, 678 (Fla. 3d DCA 2005)

Facts & Procedural History

Florida Dry Solutions, LLC, on behalf of Nelida Rodgers, appealed a county court decision regarding a property insurance claim with Citizens Property …

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Opinion of the Court

HENDON, J.

Affirmed. E. Fla. Hauling, Inc. v. Lexington Ins. Co., 913 So. 2d 673, 678 (Fla. 3d DCA 2005) (holding once an exclusion has been proven by the insurer, the burden once again is placed on the insured to demonstrate the exception to the exclusion); Fla. Windstorm Underwriting v. Gajwani, 934 So. 2d 501, 506 (Fla. 3d DCA 2005) (holding the insured has the burden to prove an exception to an exclusion contained within an insurance policy); see also Deshazior v. Safepoint Ins. Co., 305 So. 3d 752, 755 (Fla. 3d DCA 2020) (finding summary judgment proper where the insureds were unable to introduce any evidence to meet their burden of showing that the damage was not caused by an excluded event).

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