Florida Statute 627.405 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title XXXVII
INSURANCE

Chapter 627
INSURANCE RATES AND CONTRACTS

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F.S. 627.405

627.405 Insurable interest; property.—

(1) No contract of insurance of property or of any interest in property or arising from property shall be enforceable as to the insurance except for the benefit of persons having an insurable interest in the things insured as at the time of the loss.

(2) “Insurable interest” as used in this section means any actual, lawful, and substantial economic interest in the safety or preservation of the subject of the insurance free from loss, destruction, or pecuniary damage or impairment.

(3) The measure of an insurable interest in property is the extent to which the insured might be damnified by loss, injury, or impairment thereof.

History.—s. 454, ch. 59-205; s. 3, ch. 76-168; s. 1, ch. 77-457; ss. 2, 3, ch. 81-318; ss. 377, 809(2nd), ch. 82-243; s. 79, ch. 82-386; s. 114, ch. 92-318.

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Amendments to 627.405

Annotations, Discussions, Cases:

Cases Citing Statute 627.405

Total Results: 39

Cincinnati Insurance Company v. Palmer

297 So. 2d 96

District Court of Appeal of Florida | Filed: May 24, 1974 | Docket: 1033702

Cited 33 times | Published

insurable interest. Subsection (2) of F.S. Section 627.405, F.S.A. defines "insurable interest" to mean

Title & Trust Co. of Florida v. Parker

468 So. 2d 520, 10 Fla. L. Weekly 1191

District Court of Appeal of Florida | Filed: May 14, 1985 | Docket: 1402732

Cited 15 times | Published

"insurable interest" within the meaning of Section 627.405(2), Florida Statutes (1981), which requires

Life Ins. Co. of Georgia v. Lopez

443 So. 2d 947, 1983 Fla. LEXIS 3150

Supreme Court of Florida | Filed: Dec 8, 1983 | Docket: 2516525

Cited 15 times | Published

insurable interest of an applicant-beneficiary. Section 627.405, Florida Statutes (1979), by its terms only

Aetna Insurance Company v. King

265 So. 2d 716

District Court of Appeal of Florida | Filed: Aug 24, 1972 | Docket: 91780

Cited 15 times | Published

Insurance, § 478 (1971). [6] F.S. § 627.405(2), F.S.A. [7] F.S. § 627.405(3), F.S.A. [8] Aetna devotes

Stanley K. Smigiel, Et Ux. And Theresa Smigiel, His Wife v. Aetna Casualty and Surety Company

785 F.2d 922, 1986 U.S. App. LEXIS 23607

Court of Appeals for the Eleventh Circuit | Filed: Mar 31, 1986 | Docket: 1065959

Cited 14 times | Published

by loss, injury or impairment____” Fla.Stat. § 627.405(3) (1981). This second insurable interest would

Overton v. Progressive Ins. Co.

585 So. 2d 445, 1991 Fla. App. LEXIS 8569, 1991 WL 167842

District Court of Appeal of Florida | Filed: Sep 4, 1991 | Docket: 1688707

Cited 11 times | Published

destruction, or pecuniary damage or impairment. Section 627.405(2), Florida Statutes (1982). The measure of

Schlehuber v. Norfolk & Dedham Mutual Fire Ins. Co.

281 So. 2d 373, 1973 Fla. App. LEXIS 7657

District Court of Appeal of Florida | Filed: Jul 31, 1973 | Docket: 1261516

Cited 11 times | Published

right as a third party beneficiary. Fla. Stat. § 627.405, F.S.A.,[2] sets out by way of negative statement

Sun State Roofing Co., Inc. v. Cotton States Mut. Ins. Co.

400 So. 2d 842, 1981 Fla. App. LEXIS 20479

District Court of Appeal of Florida | Filed: Jul 8, 1981 | Docket: 2527874

Cited 10 times | Published

insurable interest in the damaged property. Section 627.405(2), Florida Statutes (1979), defines insurable

Travelers Indem. v. Duffy's Little Tavern

478 So. 2d 1095, 10 Fla. L. Weekly 2322, 1985 Fla. App. LEXIS 16217

District Court of Appeal of Florida | Filed: Oct 10, 1985 | Docket: 91783

Cited 8 times | Published

the property insured at the time of the loss. § 627.405(1), Fla. Stat. (1983). The measure of an insurable

One Call Property Services, Inc. a/a/o William Hughes v. Security First Insurance Company

165 So. 3d 749, 2015 Fla. App. LEXIS 7643, 2015 WL 2393353

District Court of Appeal of Florida | Filed: May 20, 2015 | Docket: 2679324

Cited 6 times | Published

explained that the legislature, in enacting section 627.405, Florida Statutes, "did not state that it was

Johnson v. Aetna Life & Cas. Co.

472 So. 2d 859, 10 Fla. L. Weekly 1741, 1985 Fla. App. LEXIS 15002

District Court of Appeal of Florida | Filed: Jul 16, 1985 | Docket: 2517766

Cited 5 times | Published

the thing *861 insured at the time of the loss. § 627.405, Fla. Stat. (1981).[1] It is clear then that a

Bioscience West, Inc. v. Gulfstream Property & Casualty Insurance Co.

185 So. 3d 638, 2016 Fla. App. LEXIS 1548, 2016 WL 455723

District Court of Appeal of Florida | Filed: Feb 5, 2016 | Docket: 3034025

Cited 4 times | Published

assignment of benefits to Bioscience violates section 627.405, Florida Statutes (2012), because Bioscience

Conyers v. Balboa Insurance

935 F. Supp. 2d 1312, 2013 WL 1233891, 2013 U.S. Dist. LEXIS 42340

District Court, M.D. Florida | Filed: Mar 26, 2013 | Docket: 65990071

Cited 4 times | Published

Plaintiffs’ Remaining Interest after Foreclosure Section 627.405, Florida Statutes, provides the basis for standing

Dyson & Co. v. FLOOD ENG., ARCH., PLAN.

523 So. 2d 756, 1988 WL 33690

District Court of Appeal of Florida | Filed: Apr 15, 1988 | Docket: 473150

Cited 4 times | Published

protected under the builders' risk policy. Section 627.405(2), Florida Statutes (1985), states: "Insurable

Spindler v. Kushner

284 So. 2d 481

District Court of Appeal of Florida | Filed: Aug 28, 1973 | Docket: 1427020

Cited 4 times | Published

have an insurable interest in the property. Section 627.405, Fla. Stat., provides: "(2) `Insurable interest'

Airvac, Inc. v. Ranger Insurance Company

266 So. 2d 178

District Court of Appeal of Florida | Filed: Aug 7, 1972 | Docket: 1298523

Cited 3 times | Published

damage or impairment." transferred to Fla. Stat. § 627.405(2) (1971), F.S.A. [4] E.g., Western Assur. Co

ASAP Restoration And Construction, Inc. a/a/o Suzanne Casey v. Tower Hill Signature Insurance Co.

165 So. 3d 756, 2015 Fla. App. LEXIS 7633

District Court of Appeal of Florida | Filed: May 20, 2015 | Docket: 2679341

Cited 2 times | Published

explained that the legislature, in enacting section 627.405, Florida Statutes, “did not state that it was

Kelly v. Balboa Insurance

897 F. Supp. 2d 1262, 2012 WL 4761905, 2012 U.S. Dist. LEXIS 86463

District Court, M.D. Florida | Filed: May 29, 2012 | Docket: 65985496

Cited 2 times | Published

standing to bring this action. Florida Statute § 627.405 provides (1) No contract of insurance of property

Accident Cleaners, Inc. v. Universal Insurance Co.

186 So. 3d 1, 2015 Fla. App. LEXIS 5199, 2015 WL 1609973

District Court of Appeal of Florida | Filed: Apr 10, 2015 | Docket: 60253688

Cited 1 times | Published

that the trial court incorrectly held that section 627.405, Florida Statutes (2013), required Appellant

Morgan v. American SEC. Ins. Co.

522 So. 2d 454, 1988 WL 20599

District Court of Appeal of Florida | Filed: Mar 15, 1988 | Docket: 1661037

Cited 1 times | Published

265 So.2d 716 *456 (Fla. 1st DCA 1972); and section 627.405(1) and (2), Florida Statutes. We affirm for

Kazi Ahmed v. Hamilton Insurance DAC

District Court of Appeal of Florida | Filed: Apr 16, 2025 | Docket: 69898821

Published

relies on the “insurable interest” provision in section 627.405. Cole does not involve a lender-placed policy

LUCILLE COVINGTON v. STATE FARM FIRE & CASUALTY CO.

District Court of Appeal of Florida | Filed: Nov 17, 2021 | Docket: 61493090

Published

585 So. 2d 445, 448 (Fla. 4th DCA 1991). Section 627.405 requires the insurable interest be present

AUNDREA COLE v. CITIZENS PROPERTY INSURANCE CORPORATION, etc.

District Court of Appeal of Florida | Filed: Aug 25, 2021 | Docket: 60290987

Published

DCA 1972). The King case is premised upon section 627.405 of the Florida Statutes that, among other

AUNDREA COLE v. CITIZENS PROPERTY INSURANCE CORPORATION, etc.

District Court of Appeal of Florida | Filed: Jun 23, 2021 | Docket: 60006533

Published

DCA 1972). The King case is premised upon section 627.405 of the Florida Statutes that, among other

ETHEL RECONCO v. INTEGON NATIONAL INSURANCE COMPANY

District Court of Appeal of Florida | Filed: Jan 27, 2021 | Docket: 45654138

Published

third-party beneficiary under the Policy pursuant to section 627.405, Florida Statutes (2018), and alleged that—at

RESTORATION 1 OF PORT ST. LUCIE, a/a/o JOHN and LIZA SQUITIERI v. ARK ROYAL INSURANCE COMPANY

255 So. 3d 344

District Court of Appeal of Florida | Filed: Sep 5, 2018 | Docket: 7804260

Published

(“[T]he sole issue before [the] court is whether section 627.405 requires a post-loss assignee to have an insurable

Emergency Services 24, Inc. a/a/o Jay Meiselman v. United Property & Casualty Ins. Co.

165 So. 3d 736, 2015 Fla. App. LEXIS 7624

District Court of Appeal of Florida | Filed: May 20, 2015 | Docket: 2679332

Published

explained that the legislature, in enacting section 627.405, Florida Statutes, "did not state that it was

Costa Del Sol Ass'n v. State, Department of Business & Professional Regulation, Division of Florida Land Sales, Condominiums, & Mobile Homes

987 So. 2d 734, 2008 Fla. App. LEXIS 9910, 2008 WL 2596215

District Court of Appeal of Florida | Filed: Jul 2, 2008 | Docket: 64855290

Published

permit their maintenance of valid insurance. See § 627.405, Fla. Stat. (2006); Brockton v. S. Life & Health

Liss v. Liss

937 So. 2d 760, 2006 Fla. App. LEXIS 14883, 2006 WL 2557958

District Court of Appeal of Florida | Filed: Sep 6, 2006 | Docket: 64846724

Published

indemnified by loss, injury, or impairment thereof. § 627.405, Fla. Stat. (2005); see also Lopez v. Life Ins

Lawyers Title Ins. Corp. v. Wells

881 So. 2d 668, 2004 WL 1906883

District Court of Appeal of Florida | Filed: Aug 27, 2004 | Docket: 1232108

Published

could not enforce the title policy pursuant to section 627.405(1), Florida Statutes. Focus Inv. Assocs., Inc

BankAmerica Housing Services v. Allstate Insurance

771 So. 2d 1218, 2000 Fla. App. LEXIS 13827, 25 Fla. L. Weekly Fed. D 2553

District Court of Appeal of Florida | Filed: Oct 27, 2000 | Docket: 64801892

Published

loss payable clause of Allstate’s policy. Section 627.405, Florida Statutes (1995), defines the term

Aetna Casualty & Surety Co. v. Growers Properties, No. 58 Ltd.

542 So. 2d 1028, 14 Fla. L. Weekly 884, 1989 Fla. App. LEXIS 1771, 1989 WL 32303

District Court of Appeal of Florida | Filed: Apr 5, 1989 | Docket: 64642251

Published

the policy was unenforceable pursuant to section 627.405(1), Florida Statutes (1983). It is significant

Lloyd v. Foremost Insurance Co.

478 So. 2d 1152, 10 Fla. L. Weekly 2622, 1985 Fla. App. LEXIS 17003

District Court of Appeal of Florida | Filed: Nov 22, 1985 | Docket: 64615733

Published

destruction, or pecuniary damage or impairment. Section 627.405, Florida Statutes (1983). Based on this statute

Corat International, Inc. v. Taylor

462 So. 2d 1186, 10 Fla. L. Weekly 196, 1985 Fla. App. LEXIS 11941

District Court of Appeal of Florida | Filed: Jan 15, 1985 | Docket: 64609612

Published

the things insured at the time of the loss." § 627.405(1), Fla.Stat. (1983). See Knott v. State ex rel

Corat International, Inc. v. Taylor

462 So. 2d 1186, 10 Fla. L. Weekly 196, 1985 Fla. App. LEXIS 11941

District Court of Appeal of Florida | Filed: Jan 15, 1985 | Docket: 64609612

Published

the things insured at the time of the loss." § 627.405(1), Fla.Stat. (1983). See Knott v. State ex rel

Cooper v. Alford

446 So. 2d 1093

District Court of Appeal of Florida | Filed: Feb 8, 1984 | Docket: 1216283

Published

Fire & Marine Insurance Co., supra, at 785. See, § 627.405, Florida Statutes (1981); 30 Fla.Jur.2d, Insurance

Underwriters at Lloyd's, London v. American Aviation Ground Services, Inc.

421 So. 2d 12, 1982 Fla. App. LEXIS 21291

District Court of Appeal of Florida | Filed: Sep 28, 1982 | Docket: 64592915

Published

provision for the benefit of the lienholder (bank). § 627.405, Fla.Stat. (1979); Cincinnati Insurance Company

Ran Investments, Inc. v. Indiana Insurance Co.

379 So. 2d 991, 1980 Fla. App. LEXIS 15488

District Court of Appeal of Florida | Filed: Jan 30, 1980 | Docket: 64574248

Published

Cannons could recover, the court stated: Fla.Stat. § 627.405, F.S.A., sets out by way of negative statement

Florida Farm Bureau Mutual Insurance v. Dyar

371 So. 2d 195, 1979 Fla. App. LEXIS 15076

District Court of Appeal of Florida | Filed: May 17, 1979 | Docket: 64570277

Published

insurable interest as mortgagor or otherwise. Section 627.405(2), Florida Statutes (1975); Aetna Ins. Co