Citizens Property Insurance Corporation v. Sandra Blanco

CourtDistrict Court of Appeal of Florida
DecidedFebruary 4, 2026
Docket3D2023-2271
StatusPublished

This text of Citizens Property Insurance Corporation v. Sandra Blanco (Citizens Property Insurance Corporation v. Sandra Blanco) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Citizens Property Insurance Corporation v. Sandra Blanco, (Fla. Ct. App. 2026).

Opinion

Third District Court of Appeal State of Florida

Opinion filed February 4, 2026. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D23-2271 Lower Tribunal No. 16-14003-CA-01 ________________

Citizens Property Insurance Corporation, Appellant,

vs.

Sandra Blanco and Carlos Luis Blanco, Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Migna Sanchez-Llorens, Judge.

Lydecker LLP, and Michelle Diverio and Alejandro Sanchez Parraga, for appellant.

Neblett Law Group, and David A. Neblett and James M. Mahaffey III, and John A. Wynn, for appellees.

Before EMAS, GORDO and BOKOR, JJ.

PER CURIAM. INTRODUCTION

Citizens Property Insurance Corp. appeals a final judgment entered by

the trial court following a jury trial and verdict in favor of the insureds, Carlos

and Sandra Blanco (collectively, “Blanco”) on their claim for breach of

contract in this first-party property insurance claim.

On appeal, Citizens asserts the trial court erred: (1) in denying Citizens’

motion for directed verdict (and subsequent motion for judgment in

accordance with its directed verdict motion) because the policy’s anti-

concurrent cause provision barred coverage for all damages; (2) by

permitting Blanco to introduce an estimate for repairs when she no longer

owned the property and had not incurred those expenses; (3) in the jury

instructions and verdict form provided to the jury on the issue of the anti-

concurrent clause; and (4) in denying Citizens’ motion for new trial based

upon improper closing by Blanco’s counsel. We find no error by the trial

court, and affirm. We write to address Citizens’ first claim on appeal—the

trial court’s denial of its motion for directed verdict and subsequent motion

for judgment in accordance with the motion for directed verdict.

FACTUAL AND PROCEDURAL BACKGROUND

The Blancos owned a home in Miami-Dade County that was insured

by Citizens during the relevant timeframes. On November 16, 2015, the

2 home sustained water damage due to a leak, and Blanco filed an insurance

claim with Citizens.

On February 26, 2016 Citizens denied Blanco’s claim “due to the fact

that the cause of loss was not covered under the policy.”

In the operative complaint, Blanco asserted a claim for breach of

contract against Citizens. Citizens answered the complaint and raised

several affirmative defenses, including that the loss was excluded under the

policy’s anti-concurrent cause provision, which states:

GENERAL EXCLUSIONS

1. We do not insure for loss caused directly or indirectly by any of the following. Such loss is excluded regardless of any other cause or event contributing concurrently or in any sequence to the loss. ... n. Constant or repeated seepage or leakage of water or steam, or in the presence of humidity, moisture or vapor, which occurs over a period of time, whether hidden or not and results in damage such as wet or dry rot, “fungi,” deterioration, rust, decay or other corrosion.

(Emphasis added).

Following a trial, the jury returned a verdict in favor of Blanco for

$61,017.51. Citizens moved for entry of judgment in accordance with their

earlier motion for directed verdict or, alternatively, for a new trial, asserting

there was no coverage under the policy because the undisputed evidence at

trial was that the leak occurred over a period of time and was a “constant or

3 repeated exposure to moisture over a period of months,” triggering the anti-

concurrent cause provision of the policy. After a hearing, the trial court

denied Citizen’s motion in its entirety, and entered final judgment in favor of

Blanco. This appeal followed.

ANALYSIS AND DISCUSSION

We review de novo the trial court’s denial of a motion for directed

verdict (and motion for judgment in accordance with motion for directed

verdict). People’s Tr. Ins. Co. v. Hernandez, 400 So. 3d 744, 746 (Fla. 3d

DCA 2024). However, we “must evaluate the evidence in the light most

favorable to the non-moving party, drawing every reasonable inference

flowing from the evidence in the nonmoving party’s favor, and ‘if there is

conflicting evidence or if different reasonable inferences may be drawn from

the evidence, then the issue is factual and should be submitted to the jury

for resolution.’” Id. at 747 (citing Miami-Dade Cnty. v. Guyton, 388 So. 3d 50,

51-52 (Fla. 3d DCA 2023)).

Citizens moved for a directed verdict during trial on the basis of an anti-

concurrent cause provision in Blanco’s policy. Specifically, Citizens argued

that the “undisputed evidence” at trial was that the leak occurred for some

period of time, that the loss and ensuing damage was the result of constant

or repeated exposure to moisture over a period of months, and that such loss

4 is not covered by the policy. Thus, Citizens contends, even if there was an

otherwise covered accidental discharge or overflow of water, the existence

of a concurring cause precluded coverage under the policy’s anti-concurrent

cause provision.

As this Court has previously explained, “‘when independent perils

converge and no single cause can be considered the sole or proximate

cause, it is appropriate to apply the concurring cause doctrine.’ However,

when the insurer explicitly avoids the application of the concurring-cause

doctrine with an anti-concurrent cause provision, the plain language of the

policy precludes recovery.” Sec. First Ins. Co. v. Czelusniak, 305 So. 3d 717,

718 (Fla. 3d DCA 2020) (quoting Sebo v. Am. Home Assurance Co., Inc.,

208 So. 3d 694, 697 (Fla. 2016)).

It is undisputed that the policy contained an anti-concurrent cause

provision. In Czelusniak, the insured’s policy also had such a provision and

because the “undisputed evidence” at trial established that the “the loss was

caused by a combination of both excluded and covered perils,” and the jury

could not “legally or factually separate the damage caused by water coming

through the door from water coming through the walls and windows,” this

court held that the trial court should have directed a verdict in the insurer’s

favor. Id. at 719.

5 Citizens asserts that the same is true in this case: there was evidence

at trial that even if there was an accidental loss arguably covered under the

policy, there was also evidence that water leakage had been taking place for

months, and that loss by “constant or repeated seepage or leakage of water.

. . over a period of time” is excluded even if it occurs concurrently with a

cause that is not excluded under the policy. Citizens contends that, due to

the anti-concurrent loss provision, the trial court should have directed a

verdict in favor of Citizens.

Blanco asserts that the undisputed evidence at trial was that the loss

was caused only by the sudden, accidental loss, with its own unique

damages, and that there was no concurrent cause. On appeal, Blanco also

contends that we cannot reverse the court’s denial of Citizens’ directed

verdict motion because Citizens failed to provide the full trial transcript, and

thus, cannot show that this loss was not solely attributable to or caused by a

sudden accidental event on November 16, 2015. In response, Citizens

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Related

John Robert Sebo v. American Home Assurance Company, Inc.
208 So. 3d 694 (Supreme Court of Florida, 2016)

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Citizens Property Insurance Corporation v. Sandra Blanco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/citizens-property-insurance-corporation-v-sandra-blanco-fladistctapp-2026.