REHAB RESTORATION, LLC, A/A/O ANDRES ARCILA
v.
CITIZENS PROPERTY INSURANCE CORPORATION
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An insurer is not required to respond within 48 hours to a demand for payment of an invoice for emergency measures already rendered; the 48-hour response obligation applies only to requests for authorization to exceed the $3,000 statutory limit.
[1] An insurer's statutory obligation to respond within 48 hours to a request for authorization to exceed the $3,000 limit for reasonable emergency measures does not extend t…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Seeking payment of an invoice for services already rendered does not equate to requesting authorization to exceed the $3,000 limit. Therefore, although Citizen[s] is required to respond within forty-eight hours to a request to exceed the $3,000 limit for reasonable emergency measures, it is not required to respond to a demand for payment of an invoice for reasonable emergency measures already rendered to an insured.”
Court's explanation of the distinction between authorization requests and payment demands under the insurance contract
Rehab Restoration sought payment from Citizens Property Insurance for emergency restoration services already provided to an insured. Citizens had subm…
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Opinion filed January 17, 2024. Not final until disposition of timely filed motion for rehearing.
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No. 3D22-2171 Lower Tribunal No. 20-22402 CC
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Rehab Restoration, LLC, a/a/o Andres Arcila,
Appellant,
vs.
Citizens Property Insurance Corporation, Appellee.
An Appeal from the County Court for Miami-Dade County, Michael G. Barket , Judge. Valiente, Carollo & McElligott, PLLC, and Caroline M. Carollo, for appellant. Methe & Rothell, P.A., and Kristi Bergemann Rothell (West Palm Beach), for appellee. Before MILLER, GORDO and BOKOR, JJ. PER CURIAM. Affirmed. See All Ins. Restoration Servs., Inc. v. Citizens Prop. Ins. Corp., 328 So. 3d 1057, 1061 (Fla. 3d DCA 2021) (“Seeking payment of an invoice for services already rendered does not equate to requesting authorization to exceed the $3,000 limit. Therefore, although Citizen[s] is required to respond within forty-eight hours to a request to exceed the $3,000 limit for reasonable emergency measures, it is not required to respond to a demand for payment of an invoice for reasonable emergency measures already rendered to an insured. As such, the trial court properly entered final summary judgment in favor of Citizens and against AIRS because under the unambiguous language in the insurance contract, Citizens satisfied its contractual obligations when it submitted the $3,000 check to AIRS.”).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- ALL Ins. Restoration Serv., Inc. v. Citizens Prop. Ins. Corp., 328 So. 3d 1057 (Fla. 3d DCA 2021)