State Farm Florida Insurance Co. v. Figueroa
218 So. 3d 886
| Fla. Dist. Ct. App. | 2017Background
- Dina Figueroa filed an insurance claim after Hurricane Wilma (Oct. 2005); State Farm inspected in Dec. 2005 and paid nothing because estimated damage was below deductible and did not request a sworn proof of loss then.
- Figueroa later faced serious health issues beginning Jan. 2006 and did not pursue the claim until she obtained a contractor estimate in late 2008 showing a replacement roof cost of $43,648.
- She reopened the claim in early 2009; State Farm inspected in April 2009, reiterated claim post-loss obligations (including submitting a sworn proof of loss within 60 days), and later provided its own proof-of-loss form.
- Figueroa submitted a proof of loss in June 2009 and a completed State Farm form in June 2010; State Farm denied coverage in June 2010 for material breach (untimely sworn proof of loss and failure to make temporary repairs); Figueroa sued.
- At trial both sides presented roofing experts on causation/damages; State Farm attacked Figueroa’s compliance with policy conditions; Figueroa introduced evidence of her medical condition to explain delay.
- Jury found Figueroa substantially complied with post-loss obligations and awarded full replacement cost; the appellate court affirmed the denial of summary judgment but reversed for a new trial because introduction of Figueroa’s health evidence was irrelevant and highly prejudicial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether insured’s untimely submission of sworn proof of loss and alleged failure to make temporary repairs precluded recovery | Figueroa: she substantially complied pre-suit and State Farm was not prejudiced by delay; health issues explain delay | State Farm: failure to timely comply with policy conditions is a material breach that bars suit | Court: denied summary judgment/directed verdict — substantial compliance and prejudice are fact questions for the jury |
| Whether evidence of insured’s medical condition was admissible to explain delay | Figueroa: medical evidence explains 3-year gap and justification for delay | State Farm: medical evidence is irrelevant and highly prejudicial | Court: admission was error; health evidence irrelevant and likely produced unfair sympathy — reversible error; new trial ordered |
Key Cases Cited
- Solano v. State Farm Fla. Ins. Co., 155 So.3d 367 (Fla. 4th DCA 2014) (substantial compliance with policy conditions is a fact question)
- Kramer v. State Farm Fla. Ins. Co., 95 So.3d 303 (Fla. 4th DCA 2012) (untimely presuit sworn proof of loss presumed prejudicial but presumption can be rebutted)
- Goldman v. State Farm Fire Gen. Ins. Co., 660 So.2d 300 (Fla. 4th DCA 1995) (failure to perform a condition precedent to suit can preclude action when obligation not performed)
- Osborne v. State, 997 So.2d 1266 (Fla. 4th DCA 2009) (admission of irrelevant, highly prejudicial evidence is harmful error)
- McDuffie v. State, 970 So.2d 312 (Fla. 2007) (definition and scope of "unfair prejudice" in evidentiary rulings)
- Special v. West Boca Med. Ctr., 160 So.3d 1251 (Fla. 2014) (reversal required where there is a reasonable possibility that improper evidence contributed to the verdict)