Florida Statutes
Fla. Stat. § 624.1551 (2025)
Civil remedy actions against property insurers.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
Find cases:
SyfertCases citing this section
FL-LEGleg.state.fl.us
JustiaFla. Statutes
CornellLII Search
CasesGoogle Scholar
624.1551 Civil remedy actions against property insurers.—Notwithstanding any provision of s. 624.155 to the contrary, in any claim for extracontractual damages under s. 624.155(1)(b), no action shall lie until a named or omnibus insured or a named beneficiary has established through an adverse adjudication by a court of law that the property insurer breached the insurance contract and a final judgment or decree has been rendered against the insurer. Acceptance of an offer of judgment under s. 768.79 or the payment of an appraisal award does not constitute an adverse adjudication under this section. The difference between an insurer’s appraiser’s final estimate and the appraisal award may be evidence of bad faith under s. 624.155(1)(b), but is not deemed an adverse adjudication under this section and does not, on its own, give rise to a cause of action.
Notes of Decisions
Cited in 7
cases (7 in the last 5 years), 2024–2025 · leading case: Newman v. Am. Home Assurance Co., Inc. (S.D. Fla. 2024).
Newman v. Am. Home Assurance Co., Inc. (S.D. Fla. 2024). “Next, American Home argues that Florida Statutes § 624.1551, which now requires an adjudication by a court of law to satisfy the first bad faith prerequisite, is a persuasive indication that the Florida Supreme Court would decline to find that an appraisal award satisfies the…”
Isaacson v. QBE Specialty Ins. Co. (M.D. Fla. 2024). “As of December 16, 2022, Fla. Stat. § 624.1551 , in its amended form, provides that a bad-faith claim “shall not lie” until the insured “has established through an adverse adjudication by a court of law that the property insurer breached the insurance contract and a final…”
Vo v. Scottsdale Ins. Co. (Fla. 1st DCA 2025). “155, Florida Statutes, on the basis that section 624.1551, Florida Statutes, requires as a prerequisite for such an action “an adverse adjudication by a court of law that the property insurer breached the insurance contract and a final judgment or decree .”
Sully v. Scottsdale Ins. Co. (S.D. Fla. 2024). “§ 624.1551). Magistrate Judge Strauss agreed.”
Rosenbaum v. QBE Specialty Ins. Co. (M.D. Fla. 2025). “” Fla. Stat. § 624.1551 (2024) (emphasis added).”
Newman v. Am. Home Assurance Co., Inc. (S.D. Fla. 2024). “Similarly, the recent state trial court decisions that American Home relies upon are inapposite because, among other reasons, they were filed after § 624.1551 took effect, unlike the instant action.”
Rosenbaum v. QBE Specialty Ins. Co. (M.D. Fla. 2025). “Under Florida Statute § 624.1551,2 a bad-faith claim “shall not lie” until the insured “has established through an adverse adjudication by a court of law that the property insurer breached the insurance contract and a final judgment or decree has been rendered against the 2 This…”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.