Supreme Court of Florida

Citizens Property Insurance Corporation v. Manor House, LLC

January 21, 2021313 So. 3d 579

Summary

The court answered the certified question in the negative and held that an insured may not recover extra-contractual consequential damages in a first-party breach of insurance contract action. Damages are limited to the amount owed under the policy's express terms, while extra-contractual damages must be pursued through a statutory bad-faith action, which is unavailable against Citizens because of its statutory immunity.