Tuesday, March 10, 2009

Confirmation of Appraisal Award Does Not Determine Liability

In State Farm Florida Ins. Co. v. Hill, 1 So.3d 1272 (Fla. 2d DCA 2009), the Second DCA vacated a circuit court order that purported to be a final judgment after the confirmation of an appraisal award. The court held the order did not clearly dispose of all issues in the case. Confirmation of an appraisal award merely determines the amount of loss and does not determine whether the insurer is liable for the damages. Therefore, judgment should not be entered based upon the confirmation of an appraisal award if coverage challenges exist.


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