efficient proximate cause doctrine (Florida) · Go Syfert
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efficient proximate cause doctrine in Florida

5 Florida opinions name it 1 courts 2013–2018 0 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (1)

CaseFollowedCited
American Home Assurance Co. v. Sebogreen
fladistctapp · 2013 · cited in 2 Florida opinions naming this issue, 2015–2016
2 sentences

2016In American Home Assurance Co. v. Sebo, 141 So.3d 195, 201 (Fla. 2d DCA 2013), rev. granted, 160 So.3d 898 (Fla.2014), this court held that in first-party claims involving multiple perils, the factfinder must apply the efficient proximate cause doctrine to determine the cause of the loss.

2016In American Home Assurance Co. v. Sebo, 141 So. 3d 195, 201 (Fla. 2d DCA 2013), rev. granted, 160 So. 3d 898 (Fla. 2014), this court held that in first-party claims involving multiple perils, the factfinder must apply the efficient proximate cause doctrine to determine the cause of the loss.

12

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
John Robert Sebo v. American Home Assurance Company, Inc. green
fla · 2016
2 sentences

2018This doctrine “provides that where there is a concurrence of different, perils, the efficient cause—the one that set the other in motion—is the cause to which the loss is attributable.” Sebo II, 208 So.3d at 697 (citing Sabella v. Nat’l Union Fire Ins.

2018Sebo II, 208 So.3d at 697 .

22018–2018
Sabella v. Wisler green
cal · 1963
2 sentences

2013If the policy excludes that peril, there is no coverage. 2 Although the efficient proximate cause doctrine has long existed in some form, its contemporary genesis is widely attributed to the California Supreme Court’s decision in Sabella v. Wisler, 59 Cal.2d 21 , 27 Cal.Rptr. 689 , 377 P.2d 889 (1963).

2013If the policy excludes that peril, there is no coverage. 2 Although the efficient proximate cause doctrine has long existed in some form, its contemporary genesis is widely attributed to the California Supreme Court’s decision in Sabella v. Wisler, 59 Cal.2d 21 , 27 Cal.Rptr. 689 , 377 P.2d 889 (1963).

12013–2013

Where else courts name it

CA 27 (1985–2024) WA 23 (1992–2023) FL 5 (2013–2018) IA 4 (2015–2019) ND 3 (2002–2005) WV 3 (1998–2025) OK 3 (2005–2018) CO 3 (1998–2008) MO 2 (1998–2019) NJ 2 (2019–2024) IL 2 (2015–2016) MI 2 (2004–2004)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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