UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
v.
GUILLERMO B. QUINTERO
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In the post-loss context, the term 'false statement' in a homeowner's insurance policy's concealment or fraud provision includes an element of intent to mislead.
[1] In the post-loss context, the term 'false statement' in a homeowner's insurance policy's concealment or fraud provision requires proof of an element of intent to mislead.
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PER CURIAM.
Affirmed. See Vargas v. Safepoint Ins. Co., No. 3D19-1656, at *2 (Fla. 3d DCA Jan. 12, 2022) (examining the “Concealment or Fraud” provision of a homeowner’s insurance policy and concluding that “the term ‘false statement’ in the post-loss context includes an element of intent to mislead”);
Anchor Prop. & Cas. Ins. Co. v. Trif, 322 So. 3d 663, 675 (Fla. 4th DCA 2021) (concluding that, “in the post-loss context, the term ‘false statement’ in the ‘Concealment or Fraud’ exclusion [of a homeowner’s insurance policy] should be interpreted as including an element of intent”).