CARLOS ALVAREZ AND YAMILKA CABRERA
v.
PEOPLE'S TRUST INSURANCE COMPANY

Fla. 3d DCA | 2022-04-13
No. 21-1127
Shea
Florida District Court of Appeal, Third District (2022)

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Holding

Failure to timely submit a sworn proof of loss when required by an insurance policy constitutes a material breach of a condition precedent that relieves the insurer of its policy duties regardless of prejudice.


Headnotes

[1] Submission of a sworn proof of loss when required by an insurance policy is a condition precedent to coverage, and material breach thereof relieves the insurer of its pol…

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Key Quotes

“It is well settled in Florida that submission of a sworn proof of loss when required by an insurance policy is a condition precedent to coverage.”

Hunt v. State Farm Fla. Ins. Co., cited as established Florida law

Facts & Procedural History

Carlos Alvarez and Yamilka Cabrera held a homeowners insurance policy with People's Trust Insurance Company. The insured failed to submit a sworn proo…

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Opinion of the Court

PER CURIAM.

Affirmed. Arguello v. People's Tr. Ins. Co., 315 So. 3d 35, 40 (Fla. 4th DCA 2021) (“To adopt the insureds’ construction of the policy would require us to add words to the policy language that ‘only’ CONDITIONS C.7 and 8 of the Duties after Loss apply when the insurer exercises its option to repair.”); Hunt v. State Farm Fla. Ins. Co., 145 So. 3d 210, 211 (Fla. 4th DCA 2014) (“It is well settled in Florida that submission of a sworn proof of loss when required by an insurance policy is a condition precedent to coverage.”

(internal citations omitted)); Am. Integrity Ins. Co. v. Estrada, 276 So. 3d 905, 915 (Fla. 3d DCA 2019) (“[W]hen an insured fails to comply with a condition precedent before filing suit, the breach is deemed material and the insurer is relieved from its policy duties irrespective of prejudice.”).


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