National Assisted Living Risk Retention Group v. Bishop, Estate of Henry Walton Bishop Jr.

District Court of Appeal of Florida·Decided August 5, 2026·No. 1D2024-1929·Published

Opinion

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA

No. 1D2024-1929

NATIONAL ASSISTED LIVING RISK RETENTION GROUP,

Appellant,

v.

HENRY WALTON BISHOP, III, individually, and as the Personal Representative of the Estate of Henry Walton Bishop, Jr., Deceased, for and on behalf of said Estate and the survivors thereof, J & S ASSISTED LIVING AND CONSULTANT LLC, a Florida limited liability company; RICHARD MARSHALL, individually; and SABRINA MARSHALL, individually,

Appellees.

On appeal from the Circuit Court for Hamilton County. Fred L. Koberlein, Jr., Judge.

August 5, 2026

ROWE, J.

National Assisted Living Risk Retention Group (NALRRG)

appeals a final judgment following proceedings supplementary by

the Estate of Henry Walton Bishop Jr. (the Estate). The Estate sued J&S Assisted Living & Consultant LLC (J&S) for the wrongful death of Bishop. After a trial, the court entered a $20 million judgment for the Estate. The Estate was then assigned J&S’s rights, interests, and claims under a 2012 insurance policy issued by NALRRG. The Estate sued NALRRG for breach of contract for denying coverage and refusing to defend J&S in the wrongful death action. After a bench trial, the court entered judgment for the Estate. NALRRG asserts that the trial court reversibly erred in finding that coverage existed under the 2012 policy assigned to the Estate because J&S never made a claim under that policy. We agree and reverse.

Bishop’s Death

In 2011, the Department of Children and Families (DCF) was called to check on the welfare of Henry Walton Bishop Jr. (Bishop), an 87-year-old man living alone in a motel room. Based on Bishop’s condition—he was unsteady on his feet, fell frequently, and became disoriented and delusional—DCF obtained an order declaring Bishop to be a vulnerable adult in need of protective services. DCF then placed Bishop in an assisted living facility owned and operated by J&S. On July 9, 2012, Bishop wandered away from J&S’s facility unsupervised and was walking to a nearby convenience store. When he tried to cross a busy intersection, he was struck by a logging truck. Bishop was pronounced dead at the scene. Florida Highway Patrol (FHP) investigated the accident and found that the driver was not at fault.

After Bishop’s death, state agencies, including FHP, DCF, and the Agency for Healthcare Administration (AHCA), opened criminal and regulatory investigations. As part of their investigations, the agencies confirmed that J&S maintained the statutorily required insurance. Richard Marshall, the facility manager for J&S, called Carmona Insurance Group (Carmona), an insurance agent, to report Bishop’s death and the ongoing investigations. At that time, no one had advised Marshall or J&S that they intended to sue or seek compensation for damages arising from Bishop’s death. Carmona’s agent told Marshall to call

back if any lawsuits were filed or charges were brought against J&S.

Insurance Policies

As it relates to this case, J&S obtained three insurance policies from NALRRG. Other than the effective date and retroactive date, the policies were materially the same. Each policy provided two forms of coverage: commercial general liability (CGL) and professional liability (PL). CGL coverage applied to “occurrences” that happened in the coverage territory during the policy period. PL coverage applied to incidents that happened within the coverage territory during the policy period.

Each form of coverage also offered J&S the option to secure supplemental extended discovery periods, also known as tail coverage, to cover claims made for incidents that happened between the retroactive date and the end of the policy period but that were not presented until after the policy period. See Arad v. Caduceus Self Ins. Fund, Inc., 585 So. 2d 1000, 1001 (Fla. 4th DCA 1991). In other words, rather than requiring an insured to report a claim for an incident that occurred during the policy period, within that same policy period, tail coverage allows an insured to report a claim—under a new policy—on a date after the expiration date of the policy in effect when the incident occurred. First Pros. Ins. Co., Inc. v. McKinney, 973 So. 2d 510, 515 (Fla. 1st DCA 2007).

2012 Policy

At the time of the incident, J&S was insured under a policy from NALRRG that was in effect from January 13, 2012, until January 13, 2013 (the 2012 policy), with a retroactive date of January 13, 2012. J&S bought the 2012 policy through DAB Premium Finance, LLC. (DAB), which gave DAB the authority to cancel the policy for nonpayment.

On December 13, 2012, NALRRG sent a letter to J&S notifying it that the 2012 policy had been cancelled because DAB reported that J&S failed to pay its premiums. The notice stated that the policy would be cancelled retroactively as of August 30, 2012. But NALRRG also advised J&S that it had the option of purchasing supplemental extended discovery coverage before

October 30, 2012, to extend the reporting period for claims that happened during the 2012 policy term. A second notice was sent on the same day also informing J&S that its 2012 policy would be retroactively cancelled as of August 30, 2012, due to DAB advising that J&S failed to pay its premiums. But this notice said that until February 11, 2013, J&S could purchase supplemental extended discovery coverage. Even so, there is no indication in the record that J&S made any effort to contact NALRRG or Carmona to buy the offered supplemental coverage.

November 2012 Renewal Letter and the 2013 Policy

In November 2012, NALRRG sent a letter to J&S, advising that the 2012 policy would expire on January 13, 2013, and offering to renew their policy for a new term. The renewal letter advised J&S that if NALRRG did not receive J&S’s application and renewal premium payment before January 13, 2013, coverage would lapse and J&S would then “have no coverage for claims resulting from an injury or incident which occurred after the expiration date.” There is no evidence that Marshall ever tried to contact NALRRG or Carmona to renew the policy before that date.

Instead, J&S did not apply for the renewal policy or pay a renewal premium until March 2013. J&S financed the premium with a different premium finance company. The 2013 policy was issued on March 8, 2013, and had a retroactive date of March 8, 2013. This created a gap in coverage from the date of cancellation of the 2012 policy (August 30, 2012) until the new policy was secured (March 8, 2013). Because of this gap, any claims made under the 2013 policy had to be tied to injuries or occurrences happening on or after March 8, 2013.

2014 Policy

J&S renewed its policy with NALRRG in 2014. J&S financed the renewal premium with yet another premium finance company. The 2014 policy had a retroactive date of March 8, 2013. This allowed J&S to report claims during the 2014 policy period (March 8, 2014, through March 8, 2015) for incidents or occurrences happening on or after March 8, 2013.

Wrongful Death Suit

Although Bishop died in July 2012, J&S did not receive any demand for damages or notice of a lawsuit until two years later. In 2014, the Estate filed a wrongful death action against J&S and Marshall. J&S and Marshall reported the lawsuit to Carmona and claimed coverage under J&S’s insurance policy with NALRRG. A third-party claims administrator denied coverage, concluding that the claim made under the 2014 policy was for an incident (Bishop’s death) that occurred before the retroactive date for reporting claims under the policy. NALRRG thus declined to represent J&S in the wrongful death action.

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National Assisted Living Risk Retention Group v. Bishop, Estate of Henry Walton Bishop Jr., (Fla. Ct. App. 2026).

National Assisted Living Risk Retention Group v. Bishop, Estate of Henry Walton Bishop Jr. (National Assisted Living Risk Retention Group v. Bishop, Estate of Henry Walton Bishop Jr.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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