The Florida Supreme Court relieved an insurance company from damages allegedly caused by its failure to timely investigate and pay a legitimate insurance claim. The property owner was not entitled to recover lost rent from its insurance carrier when the owner needed the insurance money to repair the building and the insurance carrier failed to pay the claim for more than five years.

As discussed in Citizens Property Insurance v. Manor House, Case No. SC19-1394 (January 21, 2021), Manor House obtained property insurance through Citizens—a governmental entity—for nine apartment buildings. The apartment buildings incurred significant damage from Hurricane Frances in September 2004. Following an inspection, Citizens issued payments totaling $1,927,747. Manor House requested that Citizens reopen the claim and sought damages exceeding $10,000,000. In 2006, Citizens re-adjusted the claim and informally estimated the "replacement cost value" of the loss at $6,410,456. In August 2007, Manor House filed suit demanding payment of the undisputed claim amount and requested an appraisal of the remaining portion of its claim. The trial court ordered the parties to participate in an appraisal process and, in 2009, Manor House was awarded more than $8,000,000. In January 2010—more than five years after the damage and initial insurance claim—Citizens paid Manor House an additional $5,502,022 to complete payment on the property damage claim.